Joseph Cole, LL.M has made available for download his article, “The California Office of Tax Appeals Weights in on Boyle and Electronically Filed Returns,” published on the Procedurally Taxing blog. The article begins as follows:
The Boyle Doctrine’s application to cases involving electronic filing of returns has been an issue of scholarly debate and litigation. Some of the posts on this blog covering the Boyle doctrine and its application to electronically filed returns can be found here , here, and here. The California Office of Tax Appeals (OTA) recently weighed in on the Boyle doctrine and its application to electronically filed returns in the recent Appeal of Fisher (2022-OTA-337P) decision. While the OTA ultimately ruled against the appellant taxpayer, the decision’s approach may leave room for the Boyle doctrine to be contoured to meet the realities of the age of electronic filing.
To see the full article, click here “The California Office of Tax Appeals Weights in on Boyle and Electronically Filed Returns”
Posted by Melissa Zheng, Associate Editor, Wealth Strategies Journal.