2024 Precedential Business Tax Opinions

Decisions Month Year Cite Decision Type Issues
Ajay Beri Corporation, dba Subway #23933, 28347, 10108, 10278, and 44266 September20242024-OTA-385PPending PrecedentialWhether OTA is prohibited from granting refund of criminal restitution proceeds (R&TC 7157); statute of limitations for CDTFA to issue NOD (R&TC 6487); unreported taxable sales (Subway franchises); whether court-ordered criminal restitution payments bar CDTFA from issuing NODs for period in plea agreement; weight to give evidence (plea of guilty to felony tax evasion).
M. Riedel - PFR OpinionJanuary20242024-OTA-004PPrecedentialStandard for granting petition for rehearing (insufficient evidence, contrary to law); application of payments.