Coblentz, Patch, Duffy & Bass, LLP v. City & Co. of San Francisco
Annotate this CaseThe law firm challenged the validity and scope of Proposition Q, which amended the Payroll Expense Tax Ordinance of the City and County of San Francisco (San Francisco Bus. & Tax Reg. Code, article 12-A, 901). Plaintiff paid the payroll expense tax calculated under Proposition Q, and the city rejected its Administrative claim. The firm sought a refund of that portion of the tax that it paid on the profits distributed to its equity partners. The court of appeal dismissed an appeal, ruling that some portion of the firm’s profit distributions to its equity partners represents “compensation for services,” to be included in the payroll expense tax base and that Proposition Q does not violate either article XIIIC of the California Constitution.
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