§23301

On August 1, 2008, the board suspended petitioner's corporate charter pursuant to section 23301 ofthe Suspension and Revivor article ofthe California Revenue and Taxation Code.

Forfeiture or suspension of powers, rights and privileges (a) Forfeiture or suspension of a taxpayer's powers, rights, and privileges pursuant to Section 23301 * * * shall occur and become effective only as expressly provided in this section in conjunction with Section 21020, which requires notice prior to the suspension of a taxpayer's corporate powers, rights, and privileges.[1] * * * * * * * (c) The Franchise Tax Board shall transmit the names of taxpa

Code § 23301 (West 2025). 4 These are not at issue here and have been fully assessed by respondent. 5 [*5] income tax returns. Mr. Ataya did not report dividends received from Cost U Less in either year. For tax years 2015 and 2016 Ms. Ataya reported Schedule C business income and claimed Schedule C expense deductions on her individual income tax retur

In reaching our holding we cited California Revenue and Tax Code §§ 23301 and 23302 (West 1992 & Supp.

23301 (West 2004) for failure to pay State taxes. On May 22, 2013, respondent mailed to petitioner a notice ofdeficiency determining income tax deficiencies, penalties, and additions to tax as follows: Penalty Addition to tax Year Deficiency sec. 6662(a) sec. 6651(a)(2) 2009 $368,308 $73,661 $121,684 2010 307,662 61,532 83,039 2011 335,754 71,

23301 (West 2004). The suspension remained in effect until Noveniber 26, 2014, at which time the CFTB reinstated petitioner's corporate capacity. On June 30, 2014, respondent mailed to petitioner a notice ofdeficiency determining a $1,914,668 Federal income tax deficiency for tax year ended December 31, 2011, and a section 6662(d)¹ penalty of$