BILL ANALYSIS Ó
AB 856
Page 1
Date of Hearing: May 16, 2011
ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
Henry T. Perea, Chair
AB 856 (Jeffries) - As Amended: February 17, 2011
Majority vote. Tax levy. Fiscal committee.
SUBJECT : Taxation: cancellation of indebtedness: mortgage
debt forgiveness.
SUMMARY : Conforms fully the Personal Income Tax (PIT) Law to
the Mortgage Forgiveness Debt Relief Act (MFDRA), ÝPublic Law
(P.L.) 110-142], as extended by Section 303 of the Emergency
Economic Stabilization Act of 2008 (EESA), ÝP.L. 110-343], to
allow an exclusion from gross income for cancellation of
indebtedness (COD) income generated from the discharge of
qualified principal residence indebtedness (QPRI).
Specifically, this bill :
1)Provides that Internal Revenue Code (IRC) Section 108,
relating to income from discharge of indebtedness, as amended
by Section 2 of the MFDRA, and as amended by Section 303 of
the EESA, shall apply, except as otherwise specified.
2)Applies to discharges of indebtedness occurring on or after
January 1, 2010, and before January 1, 2013.
3)Contains legislative findings and declarations stating that
the mortgage debt tax relief allowed to taxpayers in
connection with the discharge of QPRI serves a public purpose,
and does not constitute a gift of public funds.
4)Takes effect immediately as a tax levy.
EXISTING FEDERAL LAW :
1)Includes in gross income of a taxpayer an amount of debt that
is discharged by the lender (known as COD), except for any of
the following debts:
a) Debts discharged in bankruptcy;
b) Some or all of the discharged debts of an insolvent
AB 856
Page 2
taxpayer. A taxpayer is insolvent when the amount of the
taxpayer's total debts exceeds the fair market value of the
taxpayer's total assets;
c) Certain farm debts and student loans; or,
d) Debt discharge resulting from a non-recourse loan in
foreclosure. A non-recourse loan is a loan for which the
lender's only remedy in case of default is to repossess the
property being financed or used as collateral. ÝInternal
Revenue Code (IRC) Section 108].
2)Requires a taxpayer to reduce certain tax attributes by the
amount of the discharged indebtedness in the case where that
indebtedness is excluded from the taxpayer's gross income.
(IRC Section 108).
3)Excludes from a taxpayer's gross income any COD income that
resulted from a discharge of QPRI occurring on or after
January 1, 2007, and before January 1, 2013. ÝPublic Law
(P.L.) 110-12, Section 2, and P.L. 110-343, Section 303].
4)Defines "QPRI" as acquisition indebtedness within the meaning
of IRC Section 163(h)(3)(B), which generally means
indebtedness incurred in the acquisition, construction, or
substantial improvement of the principal residence of the
individual and secured by the residence. "QPRI" also includes
refinancing of such debt to the extent that the amount of the
refinancing does not exceed the amount of the indebtedness
being refinanced.
5)Allows married taxpayers to exclude from gross income up to $2
million in QPRI (married persons filing separately or single
taxpayers may exclude up to $1 million of the amount of that
indebtedness). For all taxpayers, the amount of discharge of
indebtedness generally is equal to the difference between the
adjusted issue price of the debt being cancelled and the
amount used to satisfy the debt. For example, if a creditor
forecloses on a home owned by a solvent taxpayer and sells if
for $180,000 but the house was subject to a $200,000 mortgage
debt, then the taxpayer would have $20,000 of income from the
COD.
6)Specifies that if, immediately before the discharge, only a
portion of a discharged indebtedness is QPRI, then the
AB 856
Page 3
exclusion applies only to so much of the amount discharged as
it exceeds the portion of the debt that is not QPRI. For
example, a taxpayer's principal residence is secured by an
indebtedness of $1 million, of which only $800,000 is QPRI.
If the residence is sold for $700,000 and $300,000 debt is
forgiven by the lender, then only $100,000 of the COD income
may be excluded under IRC Section 108.
7)Defines the term "principal residence" pursuant to IRC Section
121 and the applicable regulations.
8)Excludes from tax a gain from the sale or exchange of the
taxpayer's principal residence if, during the five-year period
ending on the date of the sale or exchange, the property has
been owned and used by the taxpayer as his/her principal
residence for periods aggregating two years or more. An
amount of gain eligible for the exclusion is $250,000
(taxpayers filing single) or a $500,000 (for married taxpayers
filing a joint return).
9)Requires a taxpayer to reduce the basis in the principal
residence by the amount of the excluded COD income.
EXISTING STATE LAW :
1)Conforms to the federal income tax law relating to the
exclusion of the discharged QPRI from the taxpayer's gross
income, with the following modifications:
a) The maximum amount of QPRI is reduced to $800,00
($400,000 in the case of a married/registered domestic
partner (RDP) individual filing a separate return); and,
b) For discharges occurring in 2007 or 2008, the total
amount of non-taxable COD income is limited to $250,000
($125,000 in the case of a married/RDP individual filing a
separate return).
c) For discharges occurring in 2009, 2010, 2011, or 2012,
the total amount of non-taxable COD income is limited to
$500,000 ($250,000 in the case of a married/RDP individual
filing a separate return).
2)Requires individual taxpayers to pay their estimated
California income tax in four installments over the taxable
AB 856
Page 4
year. Imposes a penalty for the underpayment of estimated
tax, which is the difference between the amount of tax shown
on the return for the taxable year and the amount of estimated
tax paid.
3)No interest or penalties are imposed on discharges of QPRI
that occurred during the 2007 or 2009 taxable year.
FISCAL EFFECT : The Franchise Tax Board (FTB) staff states that
this bill will have no impact on the General Fund revenue
because California already conforms to the provisions of the
MFDRA and EESA relating to the forgiveness of COD income and
this bill does not remove the current limitations imposed on the
amount of QPRI or COD income for purposes of the PIT law.
COMMENTS :
1)Author's Statement . The author provided the following
statement in support of this bill.
"In 2007, the federal government passed the Mortgage Forgiveness
Debt Relief Act to provide tax relief through the exclusion of
income received by the discharge of indebtedness relative to
mortgage loans. The federal government passed the act with a
bipartisan vote of 386-27.'
"This act intended to provide needed tax relief to borrowers,
homeowners, who are at great risk of losing their homes and
whose lenders agree to a short sale, a short payoff, a loan
modification or a loan refinance in which some or all of the
borrowers original debt obligation is forgiven. This
reduction in original debt is considered as income by both
federal and state law.
"California was hit harder than almost any other state when
the housing bubble burst. Home values dropped as much as 60%
from their peak in less than a year. This left many
homeowners with mortgages at amounts more than twice as much
as the value of their home. In Riverside County the median
price of home fell from $415,000 in January 2007 to only
$190,000 in January 2011. During February one out of every
163 homes in Riverside County received foreclosure filings,
and in the largest city in my district Murrieta that rose to
one in every 69. Many of my constituent whom have lost their
homes are now being hit again with taxes from the "income"
AB 856
Page 5
they received during the short-sale process.
"In 2010, the California Legislature passed SB 401 (Wolk)
which partially conformed California Tax Code to provide tax
relief but placed strict limits on both the value of the
mortgage and the amount of debt relieved. For a single
taxpayer this limit is only a mortgage of $400,000 and debt
relief of only $125,000. The average tax payers, especially
single parent homes, are hurt by California only partially
implementing this policy.
"When the legislature passed SB 401 it included a wide range
of changes beyond the mortgage debt forgiveness conformity.
Some of these conformity measures included tax increases in
order to conform to federal law but resulted in no net
increase in revenues. This allowed SB 401 to be passed with
only a majority vote last spring. Proposition 26 included a
retroactive provision which may overturn any law increasing
taxes or fee passed by a majority vote in 2010. For this
reason there is a possibility that SB 401 will be overturned
and the tax relief provided to Californians will be lost.
"AB 856 will further conform California Tax Code to federal
law. Specifically, this bill:
1. Applies to discharges of indebtedness that occur in 2009,
2010, 2011, or 2012.
2. Provides an income tax exclusion of up to $2 million
(joint) or $1 million (single) of income generated from the
discharge of qualified principal residence and
indebtedness.
3. Takes effect immediately as a tax levy.
"This bill will also address the potential reversal of the
current conformity if SB 401 is over turned due to Proposition
26. AB 856 intends to act as a vehicle that ensures
Californians will continue to receive the tax relief the
California Legislature has already guaranteed them."
2)Arguments in Support . The proponents of this bill state that
AB 856 seeks to provide full conformity to the federal rules
related to cancellation of debt income in order to grant more
tax relief to individuals who can least afford a tax bill
after losing their homes.
AB 856
Page 6
3)Mortgage Debt Forgiveness: Background . In 2008, the
Legislature approved SB 1055 (Machado), Chapter 282, Statutes
of 2008, which provided modified conformity to the MFDRA for
discharge of mortgage indebtedness in the 2007 and 2008 tax
years. Two years later, in 2010, the Legislature enacted SB
401 (Wolk), Chapter 14, Statutes of 2010 to provide homeowners
even greater assistance, not only by extending the mortgage
debt forgiveness provisions until January 1, 2013, but also by
increasing the amount of forgiven mortgage indebtedness
excludable from taxpayer's gross income from $250,000
($125,000 in the case of a married individual/RDP filing a
separate return) to $500,000 ($250,000 in case of a married
individual/RDP filing a separate return).
4)COD Income and Why Is It Taxable ? While the idea of taxing
COD income is counterintuitive to most people, the economic
theory behind existing law is sound tax policy in that it
reflects the fact that a person's net worth is increased if
his/her debt is cancelled. Under existing law, a loan amount
is not includible in the borrower's gross income; however,
when the borrower repays the loan, no deduction is allowed to
the borrower for the repayment of the principal amount of the
loan. In other words, because the borrower repays with
after-tax dollars, the amount of repayment is effectively
taxed in the year of repayment. If income is defined as a
change in a person's net worth then, by definition, a forgiven
loan is income because a cancelled debt reduces a taxpayer's
liabilities, and thus, increases his/her net worth. As noted
by Debora A. Greier, a Professor of Law of Cleveland State
University, in her statement before the United States (U.S.)
Senate Committee on Finance, without this tax rule to account
for the forgiveness and non-repayment of the loan, "the
borrower will have received permanently tax-free cash in the
year of original receipt", i.e. the year in which the borrower
received the loan.
For example, assume that a taxpayer borrowed $100,000. After
repaying $80,000 of the $100,000 borrowed, the taxpayer gets
discharged from the remaining debt. The taxpayer has COD
income of $20,000 because he/she now has $20,000 worth of
assets available to use for other purposes that were
previously committed (at least, on the balance sheet) to
repaying the loan.
5)Exceptions to COD Income Recognition . Existing law, however,
AB 856
Page 7
provides several exceptions to the general rule. Thus, a
taxpayer may exclude COD income from his/her gross income if
the debt is discharged in Title 11 bankruptcy. If the debt is
not discharged in bankruptcy, the taxpayer may exclude the COD
income if he/she is insolvent, i.e. the taxpayer's liabilities
exceed the fair market value of his/her assets, determined
immediately prior to discharge. Both exceptions, however, are
in essence deferral provisions because they require a taxpayer
to reduce certain beneficial tax attributes, including the
taxpayer's basis in property that would otherwise decrease the
taxpayer's income or tax liability in future years. Other
exceptions include COD income generated by a cancellation of
"non-recourse" debt and a cancellation of debt that was
intended to be a gift or was the result of a disputed debt. A
non-recourse loan is a loan for which the lender's only remedy
in the case of default is to repossess the property being
financed or used as collateral. That is to say that the
borrower is not personally liable for the debt and the lender
cannot pursue the homeowner personally in the case of default.
6)Non-Recourse Debt . In California, indebtedness incurred in
purchasing a home is deemed to be non-recourse debt (Code of
Civil Procedure Section 580b) and thus, generally, first
mortgages are considered to be non-recourse debt. However,
even a taxpayer with non-recourse debt must pay tax on the COD
income realized from a reduction of that debt, or part
thereof, when a lender agrees to decrease the amount of the
original debt to reflect the current value of the property
secured by the debt, because a cancellation of non-recourse
debt without a transfer of the property creates COD income for
the taxpayer in an amount equal to the amount cancelled by the
lender. Existing California law provides relief to a solvent
homeowner who refinanced the first mortgage or took out a home
equity loan or a home equity line of credit. It provides
relief to a solvent homeowner who benefited from a reduction
of his/her outstanding debt in a "workout" situation with the
lender where the homeowner retained the ownership of the home
and the lender, instead of foreclosing on the home, reduced
the outstanding debt to reflect the home's current value. For
the 2007 and 2008 tax years, California law allowed a taxpayer
to exclude from his/her gross COD income that resulted from a
discharge of QPRI, up to $250,000. ÝSB 1055 (Machado/Correa),
Chapter 282, Statutes of 2008]. In 2010, the California
Legislature increased the amount of COD income excludable from
AB 856
Page 8
tax to $500,000 for taxable years 2009, 2010, 2011, and 2012.
7)Public Policy for Excluding COD Income from Gross Income .
From a public policy perspective, a rationale given for
excluding canceled mortgage debt income has focused on
minimizing hardship for households in distress and ensuring
that homeownership retention efforts are not thwarted by tax
policy. Some argue that the exclusion of canceled residential
debt income is necessary to prevent unintended adverse
consequences resulting from foreclosure prevention efforts
especially, as lenders are being encouraged to write-down, or
work out, loans with distressed borrowers. Another stated
purpose is to prevent a reduction of consumer spending by
already financially distressed households in the wake of
foreclosures and housing market disruptions. ÝSee, e.g.
Congressional Research Service's report (CRS report) entitled
Analysis of the Proposed Tax Exclusion for Cancelled Mortgage
Debt Incom', dated January 8, 2008, p. 10]. The opponents of
the COD exclusion argue that it may make debt forgiveness more
attractive for homeowners relative to the current tax law and
may encourage homeowners to be less responsible about
fulfilling their debt obligations.
Because this bill applies to solvent taxpayers, the question
arises as to whether the solvent taxpayer deserves the tax
relief that is usually afforded only to insolvent taxpayers.
As outlined by Debora A. Greier in her statement before the
U.S. Senate Committee on Finance, existing tax law treats
personal residences as personal use assets providing personal
consumption, and therefore, personal residences are not
depreciable and losses on sale of those properties are not
deductible. In fact, tax law "assumes that any loss in value
of a personal residence is due to personal consumption rather
than market forces unrelated to the taxpayer's consumption."
However, currently, because of the unusual housing market
conditions, in many cases, the loss in value of a personal
residence is attributable to market conditions, similar to
investment property, and not due to any personal consumption
of the taxpayer. Consequently, Debora A. Greier concludes
that the only way for tax law to measure properly this
taxpayer's wealth is to exclude COD income from the taxpayer's
gross income, provided that the exclusion is a temporary
measure necessary to address the unusual market conditions.
8)QPRI Includes Secondary Loans . The exclusion for COD income
AB 856
Page 9
realized by the taxpayer from the COD applies as long as the
discharged debt was secured by a personal residence and was
incurred to acquire, construct, or substantially improve the
home, as well as debt that was used to refinance such debt.
Debt on second homes, rental property, business property,
credit cards, or car loans does not qualify for the tax-relief
provision. However, the definition of QPRI includes second
mortgages, home equity loans, and home equity lines of credit
used to improve the residence. Yet, home equity lines of
credit could have also been used to finance consumption.
Thus, existing law provides a financial incentive for
taxpayers to claim the COD income exclusion for secondary
loans even if the proceeds of those loans were used for
personal consumption.
9)What Does This Bill Intend to Accomplish? According to the
author, AB 856 is seeking to address two problems in existing
law. First, it is intended to conform fully California PIT
Law to the federal provisions related to the mortgage debt
forgiveness relief - Section 303 of P.L. 110-343, as amended
by P.L. 110-343 - without existing limitations imposed by SB
401 (Wolk). As discussed, California already provides a
similar exclusion, albeit more limited, for discharges of QPRI
that occurred in the 2007, 2008, 2009, 2010, 2011 and 2012 tax
years. The maximum amount of QPRI is set at $800,000
($400,000 in the case of a married/RDP individual filing a
separate return), and the total amount of COD income that may
be excluded is limited to $500,000 ($250,000 in the case of a
married/RDP individual filing a separate return) for 2009,
2010, 2011, and 2012 tax years, and $250,000/$125,000 in 2007
and 2008 tax years. This bill seeks to increase the amount of
QPRI to $2 million ($1 million in the case of a married
individual filing a separate return) applicable to discharges
realized on or after January 1, 2010, and before January 1,
2013, with respect to the taxpayer's primary residence, in
full conformity with the federal income tax law. It is also
intended to repeal the limitation on the amount of COD income
that may be excluded from taxation.
As currently drafted, however, this bill does not accomplish the
intended goal. It adds a new section to the Revenue &Taxation
Code to conform to the federal rules relating to mortgage
forgiveness debt relief for discharges occurring in 2010,
2011, and 2012, except as otherwise provided. In enacting SB
1055 (Machado) and SB 401 (Wolk), the Legislature expressly
AB 856
Page 10
modified the applicable federal rules and imposed certain
limitations on the amount of QPRI and COD income excludable
from taxation. Existing limitation provisions may not be
repealed by implication and will continue to apply because AB
856 does not expressly repeal those modifications. The FTB
staff suggested several technical amendments to implement the
author's intent.
Secondly, in light of the recent passage of Proposition 26, the
author believes that this measure is needed to ensure that the
COD tax relief remains available to Californians. Proposition
26 was approved by the voters on November 2, 2010. By
amending Section 3 of Article XIII A of the California
Constitution, it expanded the definition of a "tax" to include
many state and local government assessments classified as
"fees" and provided that any change in state statute that
results in any taxpayer paying a higher tax must be passed by
a two-thirds vote of the Legislature. Proposition 26 also
included a provision stating that any state law adopted
between January 1, 2010 and November 2, 2010, that conflicts
with the proposition would be repealed one year after the
proposition's approval. This repeal would not take place,
however, if the Legislature passed the law again in compliance
with Proposition 26. There is significant ambiguity regarding
the scope and meaning of this provision. According to the FTB
legal staff, there is no basis to believe that SB 401 (Wolk)
is not a valid law, at least for the 12-month period following
the adoption of Proposition 26. Furthermore, Section 3.5 of
Article III of the California Constitution requires the FTB to
enforce SB 401 (Wolk) until an appellate court has made a
determination that some portion or all of SB 401 (Wolk) is
"void" pursuant to Proposition 26 and, therefore,
unenforceable. ÝFTB publication, Legal Division Guidance
2011-01-01 'Impact of Proposition 26 on SB 401 (Wolk)'].
10)Should the Amount of QPRI Be Increased from $800,000 to $2
million ? While appreciating both the tax and public policy
objectives advanced for the enactment of the federal Act of
2007, as amended by P.L. 110-343, the Committee staff
questions whether the amount of QPRI suggested by this bill is
reasonable. The proposed $2 million limitation on the amount
of QPRI eligible for exclusion is much more than all but the
most affluent homeowners need in hardship assistance from the
state. Generally, QPRI means debt incurred in the
acquisition, construction, or substantial improvement of the
AB 856
Page 11
principal residence of the individual and secured by the
residence. According to the California Association of
Realtors (2010-11 Morning Market Forecast), the median home
price in California was $560,300 in 2007, when the market
peaked. Even the highest median price of a house in Marin
County in 2007 ($871,000) was well below the proposed QPRI
maximum of $2 million (DataQuick Information Systems). Given
that the median price of a house in most counties in 2007 was
even lower than $871,000, what kind of taxpayers need an
exemption for $2 million of QPRI?
Some analysts argue that millions of dollars in mortgages were
granted to marginal home buyers at extremely low initial
interest rates and that those mortgages were aggressively
marketed to unsophisticated buyers. Is a buyer of a
multimillion dollar house as unsophisticated as a first-time
home buyer of a more modest house? Presumably, people who buy
expensive homes have some knowledge of lending procedures and
practices, if not professional help. Generally, homeowners
with lower income experience more financial hardship,
including foreclosures. If the policy rationale for the
enactment of this bill is to minimize hardship for households
in distress, then the Committee may wish to consider whether
the proposed limits of $2 million/$1 million for the QPRI
income exclusion are appropriate and whether those limits
should be adjusted to provide relief only to those households
that are in need of state assistance.
11)Limitation on QPRI for Mortgage Interest Deduction Purposes .
Existing federal and state tax laws allow a taxpayer to claim
a deduction for mortgage interest but limit the amount of the
debt on which the accrued or paid interest may be deducted to
$1 million ($500,000 in the case of a married individual
filing separately). It is unclear why this limit was raised
to $2 million ($1 million for married individuals filing
separately) for purposes of the COD income exclusion.
Committee staff was unable to find any explanation as to why
this amount was increased for purposes of the federal Act of
2007, as amended by P.L. 110-343.
12)Should There Be a Limit on the Amount of COD Income Eligible
for the Exclusion? The median home price in California
plunged 51% from $560,300 in 2007 to $302,900 in 2010.
Arguably, the 54% decrease in value translates into
approximately $257,400 of discharged debt, and a potential
AB 856
Page 12
amount of COD income, that would be realized by the homeowner
of a house who either has found a buyer willing to pay less
than the original loan amount in a "short sale" (a sale where
the lender agrees to accept a loss in the principal amount to
be repaid in order to approve the sale) or convinced the
lender to forgive part of the principal amount of the loan on
that house.
a) High-income taxpayers benefit more than low-income
taxpayers . The proposed exclusion of unlimited COD income
disproportionately benefits taxpayers in higher tax
brackets because the "value" of an exclusion varies with
the marginal tax rate (or tax bracket) of the taxpayer.
Thus, when a taxpayer, who is in the 30% tax bracket,
excludes $100 of COD income, his/her tax is reduced by $30.
On the other hand, if the taxpayer is in a 20% bracket,
$100 of COD income excluded from his/her gross income would
reduce his/her tax liability only by $20. Because of the
progressive rate structure of the California income tax
system, taxpayers in higher tax brackets benefit more from
income exclusions than individuals in lower tax brackets.
As stated in the CRS report, this effect would be magnified
if homeownership is more concentrated among upper income
individuals. Thus, "the higher income taxpayer, with
presumably greater ability to pay taxes, receives a greater
tax benefit than the lower income taxpayer". (CRS report,
p. 8).
b) Existing tax incentives for homeowners . Existing law
already heavily subsidizes owner-occupied housing, even
without a COD income exclusion, by allowing a deduction for
mortgage interest and state and local real estate taxes,
and excluding up to 500,000/ $250,000 of gain on the sale
of a principal residence. In fact, according to the CRS
report, some analysts argue that this preferential tax
treatment encourages households to over-invest in housing
and invest less in business investments that might
contribute more to the nation's productivity and output.
13)Related Legislation .
AB 111 (Niello), introduced in the 2009-10 Legislative Session,
would have provided the same exclusion from gross income for
mortgage forgiveness debt relief that is allowed under federal
law for discharges occurring on or after January 1, 2007, and
AB 856
Page 13
before January 1, 2013. AB 111 was held by this Committee.
SB 401 (Wolk), Chapter 14, Statutes of 2010, amended the PIT Law
to conform to the federal extension of mortgage forgiveness
debt relief provided in the EESA, with the following
modifications: (a) it applies to discharges occurring in 2009,
2010, 2011, and 2012 tax years, (b) the total amount of QPRI
is limited to $800,000 ($400,000 in the case of a married
individual or domestic registered partner filing a separate
return; (c) the total amount excludable is limited to $500,000
($250,000 in the case of a married individual or domestic
registered partner filing a separate return); and (d) interest
and penalties are not imposed with respect to discharges that
occurred in the 2009 taxable year.
AB 1580 (Calderon), introduced in the 2009-2010 Legislative
Session, is similar to SB 401 (Wolk). AB 1580 was vetoed by
the governor.
SB 97 (Calderon), introduced in the 2009-10 Legislative
Session, extends the provisions of PIT Law to allow a taxpayer
to exclude from his/her gross income the COD income generated
from the discharge of QPRI in 2009, 2010, 2011, or 2012 tax
year. SB 97 never moved off the Senate Revenue & Taxation
Committee suspense file.
SB 1055 (Machado), Chapter 282, Statutes of 2008, amended the
PIT Law to conform to the federal Act of 2007, except that it
imposed certain limitations on the amount of QPRI and COD
income eligible for the exclusion. SB 1055 specified that the
exclusion applied to a discharge of QPRI that occurred in the
2007 and 2008 taxable years.
AB 1918 (Niello), introduced in the 2007-08 Legislative
Session, was similar to SB 1055. AB 1918 modified federal law
to allow the exclusion for up to $1 million/$500,000 of QPRI
and did not impose any limitations on the amount of COD
income. AB 1918 was held in this Committee.
REGISTERED SUPPORT / OPPOSITION:
Support
California Taxpayers Association
AB 856
Page 14
Opposition
None on file
Analysis Prepared by: Oksana Jaffe / REV. & TAX. / (916)
319-2098