The California Court of Appeal, without further oral argument, filed its opinion on rehearing in the matter of Gillette v. Franchise Tax Board, finding that the Multistate Tax Compact is a valid compact and California was bound by it and the Article III apportionment election provision throughout the years in question because the state had not repealed former Sec. 38001, et. seq., and withdrawn from the Compact during the tax years at issue. [Op. on Rehearing, Oct. 2, 2012] The Court's opinion on rehearing is substantially similar to its original opinion, with a few notable exceptions.