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BTLG Table of Contents > Sales and Use Tax Annotations > S > 535.0000 Successor's Liability > Annotation 535.0020

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535.0000 Successor's Liability—Regulation 1702

Annotation 535.0020

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535.0020 Fixed Assets. A sold to B and leased back the fixed assets of A's California stores; B resold the assets to A, and A sold them to C. The tax on the resale from B to A is unpaid. In such case, successor's liability cannot be asserted against either A or C under sections 6811 and 6812 because there must be a sale of the business or stock of goods for successor's liability to attach. B did not sell its business nor did it sell a stock of goods, since "stock" or "stock of goods" refers only to goods or chattels which tradesmen hold for sale. 4/22/59.