Current California “Strict Liability” Penalty Issues Under Revenue and Taxation Code Sections 19777.5 and 19138


While California’s current $26 billion budget crisis and recent legislative enactments, such as elective single factor sales and unitary credits,[1] have been the most prominent issues on the California tax front, two important and continuing penalty issues should not be overlooked. This article provides a brief update on the current status of both the 2004 so-called "amnesty interest penalty" and the 2008 underpayment penalty, both of which are imposed on a strict liability basis. Continuing, viable issues surround both penalties.

Please see full update below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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