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Hu v. City and County of San Francisco
The issue presented by this appeal is whether San Francisco’s payroll expense tax, which is assessed on all compensation paid by a business to individuals performing services for the business within the city, applies to wages and nonemployee compensation paid to the sole shareholder and principal employee of a professional corporation. The trial court ruled that the payroll expense tax applies by its terms to these types of compensation, and rejected appellant’s arguments that the city is estopped or constitutionally barred from applying that interpretation. We affirm.

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