DocuSign Envelope ID: C7E0DCCB-D547-4820-B86E-3A9CE23A23F7

OFFICE OF TAX APPEALS

STATE OF CALIFORNIA

In the Matter of the Appeal of: ) OTA Case No. 230212573

)
K. SHAH )
) POST-HEARING BRIEFING ORDER
)
)

Per the discussion during the oral hearing on January 24, 2024, the Office of Tax Appeals
(OTA) has determined that additional briefing is necessary for this appeal. (See Cal. Code
Regs., tit. 18, § 30304(a).)

REQUEST FOR APPELLANT

Please provide additional documents and evidence (including copies of correspondences, chat
messages, calendar events, contemporaneous notes, etc.) showing your efforts to ensure the
timely filing of your 2018 California income tax return and any statements from your tax
preparer regarding your California filing requirement and tax due, if any.

Appellant’s submission is due 30 days from the date of this Order and no later than
February 23, 2024. FTB will have 30 days after the acknowledged receipt of appellant’s
submission, if one is provided, to submit its reply. The parties should submit their documents
via the OTA online portal (OTAP), mail, or fax. 1
The parties shall submit any additional evidence or information responsive to this Order
to OTA by the due date specified above. The contact information for OTA is as follows:

Online: Appeal.OTA.CA.gov
Fax: (916) 492-2089
Mail: Office of Tax Appeals
P.O. Box 989880
West Sacramento, CA 95798-9880

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A tax agency may utilize an approved secure file transfer protocol (SAFE/SWIFT) when appropriate and
OTA will make a copy of the transmission available to the other party (or parties, if applicable).
DocuSign Envelope ID: C7E0DCCB-D547-4820-B86E-3A9CE23A23F7

Copies of any materials provided to OTA by a party also must be provided in a timely fashion to
the other party. The parties should contact OTA immediately if there are any questions or
concerns. Additional questions may be directed to OTA’s Ombudsperson at (916) 206-4355 or
at info@ota.ca.gov.

It is so ORDERED.

Dated: 1/25/2024
Richard Tay
Administrative Law Judge

Appeal of Shah 2