@DoninGA It's called the Bindley decision. You can read the details here: https://www.coblentzlaw.com/california-office-of-tax-appeals-gives-precedential-authority-to-bindley...
@Jester The decision you referenced applies to CA residents, not to non-residents. Two different things.
**Answers are correct to the best of my ability but do not constitute tax or legal advice.
