As we used to say in the old days: "Let's get it on!"
In the red corner. Shilling for the boys and girls at Toys R Us. Weighing in at over $4.8 million -- or, so he testifies, that's what the people of the State of California owe Toys R Us in improperly collected taxes over the past several years. Wearing the Huskie blue and white trunks. From the University of Connecticut School of Law: Professor Richard Pomp!
In the blue corner. Shilling for the residents of the State of California. Wearing the blue and gold trunks of the Mustangs. Your hometown hero. From the University of California at Davis: economics Professor Steven Sheffren.
Professor Pomp starts out with a chilling serious of body blows, testifying that the FTB's allocation of Toys R Us derivative (debt and swap) and other short-term financial income to California -- and the FTB's collection of California income tax therefrom -- was improper. But Professor Sheffren counters with crushing blow of his own, responding that the FTB's allocation was entirely proper. Hold on! Sheffren's got Pomp on the ropes! Sheffren's (persuasively) claiming that Pomp's proposed allocation would lead to absurd results! Oh, that's gotta hurt.
But wait! Pomp tags the Toys R Us lawyers! They claim that Sheffren's testimony is inadmissible because it impermissibly utilizes separate accounting! The horror! Sheffren is visibly shaken! It could be a pin! This could be the end! 1. 2 . . .
No! Sheffren get out of it! He (coyly) responds that it ain't true! The crowd goes wild! It looks like this one's gonna be close!
It's down to the refs. Which of these esteemed academics will prevail?! Will it be the East Coast Mauler and Tax Professor, Richard Pomp? Or will it be the hometown Sheffren? And Justice Raye decides . . . .
IT'S SHEFFREN!! SHEFFREN!! Sheffren is the new champion!! The economics professor beats out the tax guy! Law fails! Social science triumphs! A victory for under-paid undergraduate professors everywhere! And the FTB even recovers costs on appeal!
The drama. The excitement. Riveting.
