What is the test for "reasonable person" in the context of the California Franchise Tax Act?

MultiRegion, United States of America

The following excerpt is from Silas v. Argent Mortg. Co., 1:17-cv-00703-LJO-JLT (E.D. Cal. 2017):

reasonable person, or 'has a reasonable basis both in law and fact.'" Wertin v. Franchise Tax Bd., 68 Cal. App. 4th 961, 977 (1998) (citations omitted).

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