Sales Factor Gross Receipts Cases Addressed by the California Supreme Court

After years of litigation and speculation, the California Supreme Court issued its decisions in Microsoft Corp. v. Franchise Tax Board, 139 P.3d 1169 (Cal. 2006) (“Microsoft”) and General Motors Corp. v. Franchise Tax Board, 139 P.3d 1183 (Cal. 2006) (“General Motors”). Both cases presented the Revenue and Taxation Code section (“section”) 25120 “gross receipts” issue and the section 25137 “distortion” issue. The decisions will unquestionably have varied and widespread effects on many taxpayers doing business in California.