Swart Enterprise, Inc. v. Franchise Tax Board, 2017 Cal. App. LEXIS 21 (1/12/17). The California Court of Appeal held that an Iowa corporation that made a small investment (0.2 percent) in a California manager-managed LLC was not doing business in California for franchise tax purposes and was not required to file a corporate franchise tax return and pay the minimum franchise tax.  

IOENGINE, LLC v. Interactive Media Corp., 2017 U.S. Dist. LEXIS 758 (D. Del. 1/4/2017). An LLC’s certificate of formation was filed the day after it executed an agreement assigning a patent.