The Office of Tax Appeals posted 36 opinions to its website this week, including one “pending precedential” decision on what constitutes an “overcollection” by the Franchise Tax Board within the meaning of a technical advice memorandum (TAM) issued by the agency in 2007. This month’s opinions included 32 personal and franchise income tax cases and four appeals of business taxes, all involving common disputes and all decided unanimously in favor of the tax agencies. Most of the opinions have issuance…