Franchise Tax Board of California v. Gilbert P. Hyatt, et al. (538 U.S. 488)
U.S. Supreme Court · decided April 23, 2003 · Supreme Court Database (Spaeth)
- Citation
- 538 U.S. 488 · 123 S. Ct. 1683
- Decided
- April 23, 2003
- Term
- October Term 2002
- Vote
- 9–0
- Majority author
- Justice O'Connor
- Issue area
- Interstate Relations
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Unspecifiable
Opinion excerpt
Justice O’Connor delivered the opinion of the Court. We granted certiorari to resolve whether the Nevada Supreme Court’s refusal to extend full faith and credit to California’s statute immunizing its tax collection agency from suit violates Article IV, §1, of the Constitution. We conclude it does not, and we therefore affirm the judgment of the Nevada Supreme Court. I Respondent Gilbert P. Hyatt (hereinafter respondent) filed a “part-year” resident income tax return in California for 1991. App. to Pet. for Cert. 54. In the return, respondent represented that as of October 1, 1991, he had ceased to be a California resident and had become a resident of Nevada. In 1993, petitioner California Franchise Tax Board (CFTB) commenced an audit to determine whether respondent had underpaid state income taxes. Ibid. The audit focused on respondent’s claim that he had changed residency shortly before receiving substantial licensing fees for certain patented inventions related to computer technology. At the conclusion of its audit, CFTB determined that respondent was a California resident until April 3, 1992, and accordingly issued notices of proposed assessments for income taxes for 1991 and 1992 and imposed substantial civil fraud penalties. Id., at 56-57, 58-59. Respondent protested the proposed assessments and penalties in California through CFTB’s administrative process. See Cal. Rev.…
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