California Attorney General Opinion 23-701

TO BE PUBLISHED IN THE OFFICIAL REPORTS OFFICE OF THE ATTORNEY GENERAL State of California ROB BONTA Attorney General _______________ : OPINION : : No. 23-701 of : : July 31, 2025 ROB BONTA : Attorney General : : KARIM J. KENTFIELD : Deputy Attorney General : The HONORABLE MYRIAM BOUAZIZ, DIRECTOR OF THE OFFICE OF TAX APPEALS, has requested an opinion on a question relating to the Office’s authority. QUESTION PRESENTED AND CONCLUSION When adjudicating a taxpayer appeal, does the Office of Tax Appeals have the authority to issue a written opinion in which it concludes that applying a…