In Southern California Edison Co. v. State Board of Equalization (1972) 7 Cal.3d 652, the Supreme Court found the characterization of certain payments under income tax laws "is neither controlling, nor even particularly helpful, in the present sales and use tax context." Under income tax laws, taxpayers were often able to structure transactions to elect from a variety of tax consequences while such liberal characterization options were not available in other contexts. (Ibid.)