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Appeals › Tax Appeals › Statutory Interpretation

Pillsbury - SeeSalt Blog

Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals

Pillsbury - SeeSalt Blog on

The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the...more

Snell & Wilmer

California Office of Tax Appeals Cleared To Consider Whether Tax Regulations Conflict With Statutes

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The California Attorney General (AG) recently issued Legal Opinion No. 23-701 stating that the California Office of Tax Appeals (OTA) has the authority to determine whether tax regulations issued by the Franchise Tax Board...more

Cadwalader, Wickersham & Taft LLP

YA Global Brings its Fight to the Appellate Level

Cadwalader, Wickersham & Taft LLP on

On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

Blank Rome LLP

If You Don’t Ask, The Answer’s Always No

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One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more

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