The Ninth Circuit recently ruled that California Sales Taxes are "on or measured by income or gross receipts." In so doing, the Ninth Circuit outlined precisely what an owner (or other 'responsible person') must do in order to discharge their personal liability for a Corporation or LLC's sales taxes in the State of California. This article summarizes Ilko v. California State Board of Equalization and includes practice tips outlining what needs to occur for an owner of a business to ensure that his/her personal liability for such taxes can be discharged in bankruptcy.