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California Administrative Law

Information on locating California regulations, guidance, administrative decisions, and executive orders and proclamations online and at the UCLA Law Library.

History of California Tax Agencies

  • In 1879, an amendment to the California Constitution established the Board of Equalization to collect taxes and hear tax appeals.
  • In 1929, the California legislature created the Franchise Tax Board to collect corporate and personal income tax. Cal. Gov't Code § 11091.
  • In 2017, the California legislature concluded that the Board of Equalization had misused funds and staff and stripped it of authority over almost all taxes, except those reserved to it under the California Constitution. See Patrick McGreevy, In Massive Shakeup, Gov. Jerry Brown Breaks Up California's Scandal-Plagued Tax Collection Agency, L.A. Times, June 27, 2017, 7:55 PM.
  • To replace the Board of Equalization, the legislature created two new agencies, the Department of Tax and Fee Administration and the Office of Tax Appeals.


  • The Board of Equalization hears appeals regarding taxes on property, alcoholic beverage, and insurance. Additionally, it collects:
    • Property taxes, in collaboration with county tax assessors.
    • Alcoholic beverage taxes, in collaboration with the Department of Tax and Fee Administration.
    • Insurance taxes, in collaboration with the Department of Tax and Fee Administration, the Department of Insurance, and the State Controller's Office.
  • The Franchise Tax Board collects corporate and personal income taxes. 
  • The Department of Tax and Fee Administration collects all other taxes.
  • The Office of Tax Appeals hears appeals from the Franchise Tax Board and Department of Tax and Fee Administration.

California Tax Materials in Tax Databases

Generally, the most comprehensive sources for tax materials from all California tax agencies are the collections of tax materials provided by Checkpoint (formerly RIA), Bloomberg Law (formerly BNA), and VitalLaw (formerly CCH Intelliconnect and Wolters Kluwer Cheetah).

The materials are available at the following links:

Citing California Tax Materials

According to the California Style Manual, California tax materials should be cited if possible to the California State Tax Reporter in the format:

 Appeal of Harvey (1992) 5 SBE57 [Cal. Tax Rptr. (CCH) ¶ 402-272].

For additional details, see the relevant section of the California Style Manual:

California Board of Equalization

California Board of Equalization Decisions are comprehensively available and searchable on Westlaw, Lexis, and Nexis Uni:

The UCLA Law Library also has many Board of Equalization Opinions in print:

The Board of Equalization formerly posted its complete decisions on its website but the decisions were removed in 2019, presumably both because the Board's authority was transferred to the new Office of Tax Appeals and to comply with Cal. Gov’t Code § 11546.7, which mandates that all materials on agency websites be accessible to screen readers. See Wes Venteicher, California Disability Law Has Costly EffectsSacramento Bee, Oct. 29, 2019, 12:15 PM.

Fortunately, most historical Board of Equalization decisions remain available via the Archive of the California Government Domain, on Archive-It:

Additionally, many historical Board of Equalization decisions have been made available via the Board of Equalization's tax guides, which provide links to California tax statutes and regulations and annotations explaining how they have been interpreted. The tax guides are available for free on the websites of the Board of Equalization and the California Department of Tax and Fee Administration:

For most annotations, you can click the annotation number to access the opinion supporting it. For example, you can click the 105.0130 in the following annotation to access the Board of Equalization's 1986 decision on taxation of hot air balloons:

105.0130 Hot Air Balloons. Hot air balloons are not an "aircraft" within the meaning of section 6274. The powered heating unit installed on the hot air balloon allows the operator to control the altitude of the balloon. Horizontal movement, however, is subject to the movement of the wind or air flow. While the operator may select a course of direction by raising or lowering the balloon into the desired air flow, the actual movement and control is caused by the air flow and not a powered navigational unit. This is typified by the fact that under certain weather conditions the operator may not be able to dictate the direction of travel. 1/27/86.

California Office of Tax Appeals

Because the Office of Tax Appeals was established recently, in 2018, its opinions are readily available online from a variety of sources:

California Franchise Tax Board

Legal Rulings and Notices
Legal rulings provide general interpretations of the law by the Chief Counsel. Notices provide general information on California tax law and procedure. They are available from the following sources:

Chief Counsel Rulings

Chief counsel ruling provide advice to specific tax payers from the Chief Counsel. They are available from the following sources:

Information Letters
Information letters provide non-binding advice about a specific taxpayer's situation, at the request of the taxpayer or their representatives. They are available from the following sources:

Technical Advice Memorandum

Technical advice memorandum provide advice about specific tax payers and are written by the FTB legal department at the request of other FTB staff. They are available from the following sources: