Formal & Memorandum Opinions

The Board of Equalization hears appeals related to the constitutional duties of the Board, including Property Tax, Alcoholic Beverage Tax, and the Tax on Insurers (Insurance Tax).

To date, the Board has not issued a Memorandum Opinion on Property Tax or Alcoholic Beverage Tax appeals.

Please note that, as of January 1, 2018, the Board of Equalization does not have adjudicatory responsibility for Business Tax or Franchise & Income Tax Cases. Please contact the Office of Tax Appeals (OTA) with any questions regarding Business or Franchise & Income Tax cases, including determining whether a historic Board of Equalization Formal or Memorandum opinion can be used in an adjudicatory matter before OTA. Additionally, Historic Business Tax Opinions may be found in the California Department of Tax and Fee Administration’s (CDTFA’s) Business Taxes Law Guide.

If you would like to request a copy of a historic Board of Equalization opinion, please contact

Insurance Tax Memorandum Opinions

The Board hears Insurance Taxpayer appeals and makes decisions to grant or deny petitions for redetermination and claims for refund.

The Board issues Memorandum Opinions as a means of resolving selected cases. Taxpayers may look to Memorandum Opinions for guidance as to the Board’s position on the legal issues discussed in those opinions. If a Memorandum Opinion presents facts and/or legal issues similar to those in a pending appeal, the Board will generally rely on the Memorandum Opinion to make its determination in the pending appeal.

(Please note that there were no Memorandum Opinions adopted by the Board for any years not listed.)