’Precedent’ Applied Retroactively to Negate Taxpayer’s Successful Appeal
The Office of Tax Appeals posted 36 opinions on its website for May, including a ruling that reversed a taxpayer’s partial win based on a precedential decision released after the ruling. In the Appeal of A. Edwards, the OTA’s initial ruling, dated February 1, 2021, sided with the Franchise Tax Board on most issues but concluded that the “demand penalty” should be abated, using similar logic applied in a majority of the cases on the demand penalty up to that…