Formal & Memorandum Opinions - Board of Equalization

Franchise & Income Tax Formal Legal Opinions  |  Business Taxes Memorandum Opinions

Franchise & Income Tax Formal Legal Opinions

Corporate and individual taxpayers who dispute a final determination by the Franchise Tax board may appeal that determination to the Board of Equalization (the Board). The Board issues Formal Opinions as a means of resolving selected cases. Taxpayers may look to Formal Opinions for guidance as to the Board's position on the legal issues discussed in those opinions. If a Formal Opinion presents facts and/or legal issues similar to those in a pending appeal, the Board will generally rely on the Formal Opinion to make its determination in the pending appeal. The more recent Formal Opinions are now available on this Website, and we anticipate that all Formal Opinions issued by the Board will be available in the very near future.

Please select the year of the Franchise and Income Tax Legal Opinions that you wish to view or print from the table below:

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Business Taxes Memorandum Opinions

The Board uses the term business taxes to refer to matters involving sales and use taxes, local and district tax reallocations, and the various special taxes and fees administered by the Board. Taxpayers and feepayers who disagree with denials of claims for refund or determinations issued by the Sales and Use Tax Department or the Special Taxes Divisions of the Board may appeal such actions to the elected members of the Board. Additionally, jurisdictions (e.g., cities and counties) that disagree with determinations issued by the Sales and Use Tax Department related to reallocations of local or district taxes may also appeal to the Board. The Board issues Memorandum Opinions as a means of resolving selected cases, which are appealed to the elected members. Taxpayers and feepayers may look to the Memorandum Opinions for guidance as to the Board's position on the legal issues discussed in those opinions. If a Memorandum Opinion presents facts and/or legal issues similar to those in a pending appeal, the Board will generally rely on that Memorandum Opinion to make its determination in the pending appeal.

Please select the year to view or print memorandum opinions adopted by the Board of Equalization during that year. (Please note that there were no memorandum opinions adopted by the Board for the years not listed.)