California AG Boosts Office of Tax Appeals’ Judicial Scope (1)

Aug. 6, 2025, 9:26 PM UTCUpdated: Aug. 6, 2025, 9:43 PM UTC

The California Office of Tax Appeals holds full authority to issue written opinions that decline to enforce regulations issued by the state’s two other tax agencies, state Attorney General Rob Bonta found in an opinion addressing the agency’s scope of authority.

Bonta’s ruling settles a longstanding disagreement with taxpayers in which OTA asserted it lacked authority to strike down regulations issued by California’s Franchise Tax Board and the California Department of Tax and Fee Administration. Various business groups, including the California Taxpayers Association, had objected to OTA’s position, arguing the agency’s indecision forces taxpayers to resolve their regulatory disputes in ...

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