CA Franchise Tax Board (FTB) may fight you to the bitter end, regardless of cost!
"The supreme art of war is to subdue the enemy without fighting."
- Sun Tzu, The Art of War
Knowing or believing the FTB will challenge an appeal at the various levels causes most taxpayers to pay the tax and move on. Given the FTB may continue to pursue the collection of a debt for 20 years also causes taxpayers to just pay and move on. There are many stories of taxpayers paying assessed taxes when there is a high probability they could win on appeal. Why don't they fight? Time, value and money. There are some taxpayers, however, who will fight the fight regardless of cost or time, because of general principle, or to set a precedent.
Keep in mind, the FTB is responsible for administering the income tax laws and collecting taxes owed to the state of California. The FTB's authority to settle is limited however they can settle. The tweet by CalTax below includes a link to a YouTube interview featuring Teresa Casazza. It illustrates the point that FTB should consider reviewing their settlement procedures when processing appeals. Check it out!
Master Steve Sims, EA (Smile)
CalTax (@CalTax) 5/10/17, 11:11 AM
CalTax urges FTB to enhance settlementto avoid lengthy appeals that cost more than the amount in dispute. youtu.be/QpVaBiOKKkQ