How has the issue been treated in the courts?
California, United States of America
The following excerpt is from Lennane v. Franchise Tax Bd., 51 Cal.App.4th 1180, 59 Cal.Rptr.2d 602 (Cal. App. 1996):
4 As taxpayers themselves surmise, both appellate courts may well have deemed the issue inadequately presented because set out not in the body of the briefs, but in a footnote to the background facts. (Cf. Stoll v. Shuff (1994) 22 Cal.App.4th 22, 25, fn. 1, 27 Cal.Rptr.2d 249; People v. Freeman (1994) 8 Cal.4th 450, 482, fn. 2, 34 Cal.Rptr.2d 558, 882 P.2d 249.)
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