BILL ANALYSIS                                                                                                                                                                                                    �







                      SENATE COMMITTEE ON PUBLIC SAFETY
                            Senator Loni Hancock, Chair              A
                             2013-2014 Regular Session               B

                                                                     7
                                                                     8
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          AB 781 (Bocanegra)                                          
          As Amended April 18, 2013 
          Hearing date:  July 2, 2013
          Revenue and Taxation Code
          AA:mc

                                      TAX FRAUD:

                              SALES SUPPRESSION DEVICES

                                           
                                       HISTORY

          Source:  State Board of Equalization

          Prior Legislation: None

          Support: California Retailers Association; American Federation  
          of State, County, and                                  Municipal  
          Employees; California Grocers Association; California State  
          Association of Counties; Los Angeles County District Attorney  
          (if amended)

          Opposition:Taxpayers for Improving Public Safety

          Assembly Floor Vote:  Ayes  75 - Noes  1


                                         KEY ISSUE
           
          SHOULD NEW CRIMES BE ENACTED TO PROHIBIT THE PURCHASE, INSTALLATION,  
          TRANSFER OR POSSESSION OF SOFTWARE PROGRAMS THAT FALSIFY REPORTED  
          SALES, AS SPECIFIED?




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                                       PURPOSE

          The purpose of this bill is to enact new crimes (wobblers) for  
          any person to knowingly sell, purchase, install, transfer or  
          possess software programs that falsify reported sales, as  
          specified.

           Current law  generally provides that any person required to make,  
          render, sign, or verify any report who makes any false or  
          fraudulent tax return, with intent to defeat or evade the  
          determination of an amount due required by law to be made is  
          guilty of a misdemeanor punishable by a fine of not less than  
          $1,000 and not more than $5,000, or imprisonment not exceeding  
          one year in the county jail, or both the fine and imprisonment  
          in the discretion of the court.  (Revenue and Taxation Code ��  
          7152(a) and 7153.)
           
           Current law  provides that any person who willfully aids or  
          assists in, or procures, counsels, or advises in, the  
          preparation or presentation, in connection with any matter  
          arising under this part, of a return, affidavit, claim, or other  
          document that is fraudulent or false as to any material matter,  
          whether or not the falsity or fraud is with the knowledge or  
          consent of the person authorized or required to present the  
          return, affidavit, claim, or document, is guilty of a  
          misdemeanor punishable  by a fine of not less than $1,000 and  
          not more than $5,000, or imprisonment not exceeding one year in  
          the county jail, or both the fine and imprisonment in the  
          discretion of the court.  (Revenue and Taxation Code � 7152(b)  
          and 7153.)

           Current law  generally provides that any person who violates  
          these provisions "with intent to defeat or evade the reporting,  
          assessment, or payment of a tax or an amount due required by law  
          to be made is guilty of a felony when the amount of unreported  
          tax liability aggregates . . . $25,000 or more in any  
          12-consecutive-month period.  Each offense shall be punished by  
          a fine of not less than . . . $5,000 and not more than . . .  




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          $20,000, or imprisonment for 16 months, two years, or three  
          years, or both the fine and imprisonment in the discretion of  
          the court."  (Revenue and Taxation Code � 7153.5.)

           Current law  imposes a penalty of 25 percent of the amount of any  
          tax deficiency due to fraud or an intent to evade existing laws,  
          as specified.  (Revenue and Taxation Code � 6485.)  

           Current law  , the "Fee Collection Procedures Law," provides that  
          any "person who knowingly or willfully files a false return or  
          report with the board, and any person who refuses to permit the  
          board or any of its authorized representatives to make any  
          inspection or examination for which provision is made in this  
          part, or who fails to keep any records prescribed by the board,  
          or who fails to preserve the records for the inspection of the  
          board for the time that the board deems necessary, or who  
          alters, cancels, or obliterates entries in the records for the  
          purpose of falsifying the records, is guilty of a misdemeanor  
          and shall be punished by a fine of not less than . . . $100 or  
          more than $1,000, by imprisonment in the county jail for not  
          less than one month or more than six months, or by both."   
          (Revenue and Taxation Code � 55362.)

           Current law  further provides that any person who willfully  
          evades or attempts in any manner to evade or defeat the payment  
          of the fee imposed by this part is guilty of a felony punishable  
          by imprisonment pursuant to subdivision (h) of Section 1170 of  
          the Penal Code for 16 months, two, or three years and a fine of  
          not more than . . . $5,000.  (Revenue and Taxation Code �  
          55363.)

           This bill  would enact two new crimes pertaining to the use of  
          specified technology designed for purposes related to  
          underreporting tax liabilities.  Specifically:

           This bill  would provide that "a person who knowingly sells,  
          purchases, installs, transfers, possesses, or uses in this state  
          any automated sales suppression device or zapper or phantom-ware  
          is guilty of an offense punishable by a fine of not more than .  
          . . $10,000, by imprisonment in a county jail for not more than  




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          one year, or, pursuant to subdivision (h) of Section 1170 of the  
          Penal Code, for 16 months, or two, or three years, or by both  
          that fine and imprisonment."

           This bill  would provide that, in "addition, any person who uses  
          an automated sales suppression device or zapper or phantom-ware  
          shall be liable for all taxes, interest, and penalties due as a  
          result of the use of that device."

           This bill  would enact the following definitions for purposes of  
          these provisions:

               (1) "Automated sales suppression device" or "zapper"  
               means a software program carried on a memory stick or  
               removable compact disc, accessed through an Internet  
               link, or accessed through any other means, that  
               falsifies the electronic records of electronic cash  
               registers and other point-of-sale systems, including,  
               but not limited to, transaction data and transaction  
               reports.

               (2) "Electronic cash register" means a device that  
               keeps a register or supporting documents through the  
               means of an electronic device or computer system  
               designed to record transaction data for the purpose of  
               computing, compiling, or processing retail sales  
               transaction data in whatever manner.

               (3) "Phantom-ware" means a hidden, preinstalled, or  
               installed at a later time programming option embedded  
               in the operating system of an electronic cash register  
               or hardwired into the electronic cash register that  
               can be used to create a virtual second till or may  
               eliminate or manipulate transaction records that may  
               or may not be preserved in digital formats to  
               represent the true or manipulated record of  
               transactions in the electronic cash register.

               (4) "Transaction data" includes information regarding  
               items purchased by a customer, the price for each  




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               item, a taxability determination for each item, a  
               segregated tax amount for each of the taxed items, the  
               amount of cash or credit tendered, the net amount  
               returned to the customer in change, the date and time  
               of the purchase, the name, address, and identification  
               number of the vendor, and the receipt or invoice  
               number of the transaction. 

           This bill  additionally would provide that "a person who  
          knowingly sells, purchases, installs, transfers, possesses, or  
          uses in this state any automated sales suppression device or  
          zapper or phantom-ware is guilty of an offense punishable by a  
          fine of not more than . . .  $10,000, by imprisonment in a  
          county jail for not more than one year, or, pursuant to  
          subdivision (h) of Section 1170 of the Penal Code, for 16  
          months, or two, or three years, or by both that fine and  
          imprisonment."

           This bill  would provide, in "addition, any person who uses an  
          automated sales suppression device or zapper or phantom-ware  
          shall be liable for all taxes, interest, and penalties due as a  
          result of the use of that device."

           This bill  would enact the same definitions enumerated above for  
          purposes of these provisions, except for the following  
          definition of "transaction data":

                 "Transaction data" includes information regarding items  
               purchased by a customer, the price for each item, a  
               taxability determination for each item, a segregated tax or  
               fee amount for each of the items subject to the tax or fee,  
               the amount of cash or credit tendered, the net amount  
               returned to the customer in change, the date and time of  
               the purchase, the name, address, and identification number  
               of the vendor, and the receipt or invoice number of the  
               transaction. 

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the last several years, severe overcrowding in California's  




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          prisons has been the focus of evolving and expensive litigation  
          relating to conditions of confinement.  On May 23, 2011, the  
          United States Supreme Court ordered California to reduce its  
          prison population to 137.5 percent of design capacity within two  
          years from the date of its ruling, subject to the right of the  
          state to seek modifications in appropriate circumstances.   

          Beginning in early 2007, Senate leadership initiated a policy to  
          hold legislative proposals which could further aggravate the  
          prison overcrowding crisis through new or expanded felony  
          prosecutions.  Under the resulting policy known as "ROCA" (which  
          stands for "Receivership/ Overcrowding Crisis Aggravation"), the  
          Committee held measures which created a new felony, expanded the  
          scope or penalty of an existing felony, or otherwise increased  
          the application of a felony in a manner which could exacerbate  
          the prison overcrowding crisis.  Under these principles, ROCA  
          was applied as a content-neutral, provisional measure necessary  
          to ensure that the Legislature did not erode progress towards  
          reducing prison overcrowding by passing legislation which would  
          increase the prison population.  ROCA necessitated many hard and  
          difficult decisions for the Committee.

          In January of 2013, just over a year after the enactment of the  
          historic Public Safety Realignment Act of 2011, the State of  
          California filed court documents seeking to vacate or modify the  
          federal court order issued by the Three-Judge Court three years  
          earlier to reduce the state's prison population to 137.5 percent  
          of design capacity.  The State submitted in part that the, ". .  
          .  population in the State's 33 prisons has been reduced by over  
          24,000 inmates since October 2011 when public safety realignment  
          went into effect, by more than 36,000 inmates compared to the  
          2008 population . . . , and by nearly 42,000 inmates since 2006  
          . . . ."  Plaintiffs, who opposed the state's motion, argue in  
          part that, "California prisons, which currently average 150% of  
          capacity, and reach as high as 185% of capacity at one prison,  
          continue to deliver health care that is constitutionally  
          deficient."  In an order dated January 29, 2013, the federal  
          court granted the state a six-month extension to achieve the  
          137.5 % prisoner population cap by December 31st of this year.  





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          In an order dated April 11, 2013, the Three-Judge Court denied  
          the state's motions, and ordered the state of California to  
          "immediately take all steps necessary to comply with this  
          Court's . . . Order . . . requiring defendants to reduce overall  
          prison population to 137.5% design capacity by December 31,  
          2013."         

          The ongoing litigation indicates that prison capacity and  
          related issues concerning conditions of confinement remain  
          unresolved.  However, in light of the real gains in reducing the  
          prison population that have been made, although even greater  
          reductions are required by the court, the Committee will review  
          each ROCA bill with more flexible consideration.  The following  
          questions will inform this consideration:

                 whether a measure erodes realignment;
                 whether a measure addresses a crime which is directly  
               dangerous to the physical safety of others for which there  
               is no other reasonably appropriate sanction; 
                 whether a bill corrects a constitutional infirmity or  
               legislative drafting error; 
                 whether a measure proposes penalties which are  
               proportionate, and cannot be achieved through any other  
               reasonably appropriate remedy; and
                 whether a bill addresses a major area of public safety  
               or criminal activity for which there is no other  
               reasonable, appropriate remedy.

                                      COMMENTS

          1.  Stated Need for This Bill

           The author states:

               California's tax system is based on the principal of  
               voluntary contribution.  Most taxpayers comply with  
               the law.  However, some taxpayers cheat the system by  
               omitting certain sales and as a way of evading taxes.   
               This is especially true for cash businesses that don't  
               always ring up sales.  This process generally required  




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               maintaining two sets of books, one for the BOE and  
               IRS, and one for the store owner which provides actual  
               sales.  This process used to be very labor intensive  
               and discouraged many from attempting to omit a  
               percentage of sales.  However, the process is now  
               incredibly easy to accomplish because of new  
               electronic record keeping systems.  These kinds of  
               devices have been referred to as "zappers" or "sales  
               suppression devices."  It is now incredibly easy for a  
               store owner to delete a percentage of sales.  In fact,  
               depending on the program, a store owner can now enter  
               the percentage of sales to be omitted and keep two  
               sets of books that can be updated on a regular basis.   
               Even if a business is audited, it is incredibly  
               difficult for tax auditor to detect the zapper program  
               or any irregularities in the sales record.   
               Additionally, the process of deleting sales is already  
               illegal.  A seller must disclose all income and remit  
               all sales taxes collected.  However, because the  
               programs are difficult to detect, even if the business  
               is audited, it is important that we make the sale and  
               use of these devices illegal.  This prevents dishonest  
               taxpayers from ever obtaining these kinds of programs.

          2.  Double-Referral

           This bill was heard on June 19, 2013, by the Senate Committee on  
          Governance and Finance.  That Committee passed this bill by a  
          vote of 6-0.

          3.  Background on the Problem

           As noted by the author, technology has provided more  
          sophisticated methods for evading taxes.  As explained in a 2009  
          paper on this issue:

               Skimming cash receipts is an old fashioned tax fraud;  
               a fraud traditionally associated with small or medium  
               sized enterprises.  Large businesses with formalized  
               internal control mechanisms, external accountants, and  




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               professional management structures do not normally  
               engage in skimming, although personal conversations  
               with auditors from Revenue Quebec indicate that this  
               may not be a solid assumption any more.  Businesses  
               that skim frequently keep two sets of books (one for  
               the tax man, the other for the owner).  In its  
               simplest (nontechnological) form there are two tills,  
               and the cashier simply diverts some cash from selected  
               sales into a secret drawer.  A record of the diversion  
               may be maintained, but it will be kept outside the  
               formal accounting system.  Businesses that skim rarely  
               do so with credit card transactions precisely because  
               these sales can be documented externally through the  
               banking system.  Skimming frauds thrive when the owner  
               (or a close family member) is the cashier.

               Technology is changing how businesses skim.  The  
               agents of change are software
               applications - phantom-ware and zappers.  Phantom-ware  
               is a "hidden," pre-installed programming option(s)  
               embedded within the operating system of a modern  
               electronic cash register (ECR).  It can be used to  
               create a virtual second till and may preserve a  
               digital (off-line) record of the skimming (a second  
               set of digital books).  The physical diversion of  
               funds into a second drawer is no longer required, and  
               the need for manual recordkeeping of the skim is  
               eliminated.  Because phantom-ware programming is part  
               of the operating system of an ECR its use can be  
               detected with the assistance of a computer audit  
               specialist.

               Zappers are more advanced technology than  
               phantom-ware.  Zappers are special
               programming options added to ECRs or point of sale  
               (POS) networks.  They are carried on memory sticks,  
               removable CDs or can be accessed through an internet  
               link.  Because zappers are not integrated into  
               operating systems their use is more difficult to  
               detect.  Zappers liberate owners from the need to  




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               personally operate the cash register.  Remote skimming  
               of cash transactions is now possible without the  
               knowing participation of the cashier who physically  
               rings up the sale.  This attribute of zappers allows  
               the incidence of skimming fraud to migrate
               beyond the traditional "mom and pop" stores.  Zappers  
               allow owners to place employees at the cash register,  
               check their performance (monitor employee theft), but  
               then remotely skim sales to cheat the taxman.<1>

          4.  Intent
           
          As currently drafted, the crimes this bill would enact would be  
          strict liability crimes - that is, no intent to commit or  
          facilitate tax fraud would be required.  The current tax fraud  
          crimes require "intent to defeat or evade the determination of  
          an amount due required by law to be made . . . ."  In addition,  
          current law makes it a crime for a person who "willfully aids or  
          assists in, or procures, counsels, or advises in,  . . . "  
          fraudulent tax documents, as specified.

          As explained in a 2004 California Supreme Court decision:

               For criminal liability to attach to an action, the  
               standard rule is that "there must exist a union, or  
               joint operation of act and intent, or criminal  
               negligence."  (Pen. Code, � 20.)  "[T]he requirement  
               that, for a criminal conviction, the prosecution prove  
               some form of guilty intent, knowledge, or criminal  
               negligence is of such long standing and so fundamental  
               to our criminal law that penal statutes will often be  
               construed to contain such an element despite their  
               failure expressly to state it. 'Generally, "'[t]he  
               existence of a mens rea is the rule of, rather than  
               the exception to, the principles of Anglo-American  
               criminal jurisprudence.' ?"  [Citation.] In other  
               ----------------------
          <1>   Ainsworth, California Zappers: A Proposal for California's  
          Commission on the 21st Century Economy
          (Boston University School of Law Working Paper No. 09-01,  
          January 8, 2009 (footnotes omitted).)



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               words, there must be a union of act and wrongful  
               intent, or criminal negligence.  [Citations.]  "So  
               basic is this requirement that it is an invariable  
               element of every crime unless excluded expressly or by  
               necessary implication."  [Citation.]'  [Citation.]"   
               (In re Jorge M. (2000) 23 Cal.4th 866, 872 [98 Cal.  
               Rptr. 2d 466, 4 P.3d 297] (Jorge M.); see 1 Witkin &  
               Epstein, Cal. Criminal Law (3d ed. 2000) Elements, �  
               1, pp. 198-199.) 

               The prevailing trend in the law is against imposing  
               criminal liability without proof of some mental state  
               where the statute does not evidence the Legislature's  
               intent to impose strict liability.  (People v. Simon  
               (1995) 9 Cal.4th 493, 521 [37 Cal. Rptr. 2d 278, 886  
               P.2d 1271]; Liparota v. United States (1985) 471 U.S.  
               419, 426 [85 L. Ed. 2d 434, 105 S. Ct. 2084]  
               [extension of strict liability crimes disfavored]; see  
               1 Witkin & Epstein, Cal. Criminal Law, supra,  
               Elements, � 18, p. 223 [examples given of strict  
               liability crimes are not "indicative of a trend.   
                                                                                              Indeed, the opposite appears to be true"].)

               "Equally well recognized, however, is that for certain  
               types of penal laws, often referred to as public  
               welfare offenses, the Legislature does not intend that  
               any proof of scienter or wrongful intent be necessary  
               for conviction.  'Such offenses generally are based  
               upon the violation of statutes which are purely  
               regulatory in nature and involve widespread injury to  
               the public.  [Citation.]  "  Under many statutes enacted  
               for the protection of the public health and safety,  
               e.g., traffic and food and drug regulations, criminal  
               sanctions are relied upon even if there is no wrongful  
               intent.  These offenses usually involve light  
               penalties and no moral obloquy or damage to  
               reputation  .  Although criminal sanctions are relied  
               upon, the primary purpose of the statutes is  
               regulation rather than punishment or correction.  The  
               offenses are not crimes in the orthodox sense, and  




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               wrongful intent is not required in the interest of  
               enforcement  ."'" (Jorge M., supra, 23 Cal.4th at p.  
               872.) . . .<2>
            
          As now drafted, this bill would impose a misdemeanor or a felony  
          - both with incarceration penalties and significant criminal  
          fines - for a person to sell, purchase, install, transfer, use  
          or possess one of the proscribed devices without requiring a  
          showing of intent to commit or facilitate tax fraud.  Thus, this  
          bill could subject a small restaurant owner, for example, to  
          felony liability if he or she was offered such a device and, to  
          avoid confrontation, accepted the device and stashed it away in  
          a drawer with no intent to ever use it.  Similarly, this bill  
          could subject someone to felony liability if there is a device  
          installed on their cash register and they have no knowledge of  
          its purpose or function - for example, a sole proprietor whose  
          son or daughter does their bookkeeping, and encourages them to  
          "update" their software.  Without requiring any showing of  
          intent, this bill would criminalize unwitting passivity where  
          there was no intent on the part of the shop owner to commit tax  
          fraud.    

          Comment 7 below contains draft amendments agreed to by the  
          author which would address these issues in a manner consistent  
          with the goals of the bill.  
           
          5.  Penalties

           As explained in detail above, making a fraudulent tax return is  
          a crime under current law.  Penalties currently are misdemeanor  
          and civil, unless the amount of the tax fraud aggregates at  
          $25,000 or more in a 12-month period, in which case the crime is  
          a felony punishable by $5,000 to $20,000 in fines and/or a  
          sentence of 16 months, two or three years.   

          This bill would enact two discrete crimes in the Revenue and  
          Taxation Code specifically proscribing automated sales  
          suppression devices.  The following chart summarizes current law  
          and this bill:


          ---------------------------
          <2>   In re Jennings, 34 Cal. 4th 254 (2004) (emphasis added.) 



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           ----------------------------------------------------------------- 
          |      Provision      |   Prohibited Act    |       Penalty       |
          |---------------------+---------------------+---------------------|
          |Current law --       |Make any false or    |Misdemeanor: fine of |
          |Revenue and Taxation |fraudulent tax       |not less than $1,000 |
          |Code �� 7152(a) and  |return, with intent  |and not more than    |
          |7153.                |to defeat or evade   |$5,000, or           |
          |                     |the determination of |imprisonment not     |
          |                     |an amount due        |exceeding one year   |
          |                     |required by law to   |in the county jail,  |
          |                     |be made.             |or both the fine and |
          |                     |                     |imprisonment in the  |
          |                     |                     |discretion of the    |
          |                     |                     |court.               |
          |                     |                     |                     |
          |---------------------+---------------------+---------------------|
          |Current law --       |Willfully aid or     |Misdemeanor: fine of |
          |Revenue and Taxation |assist in, or        |not less than $1,000 |
          |Code �� 7152(b) and  |procure, counsel, or |and not more than    |
          |7153.                |advise in, the       |$5,000, or           |
          |                     |preparation or       |imprisonment not     |
          |                     |presentation, in     |exceeding one year   |
          |                     |connection with any  |in the county jail,  |
          |                     |matter arising under |or both the fine and |
          |                     |this part, of a      |imprisonment in the  |
          |                     |return, affidavit,   |discretion of the    |
          |                     |claim, or other      |court.               |
          |                     |document that is     |                     |
          |                     |fraudulent or false  |                     |
          |                     |as to any material   |                     |
          |                     |matter, whether or   |                     |
          |                     |not the falsity or   |                     |
          |                     |fraud is with the    |                     |
          |                     |knowledge or consent |                     |
          |                     |of the person        |                     |
          |                     |authorized or        |                     |
          |                     |required to present  |                     |
          |                     |the return,          |                     |
          |                     |affidavit, claim, or |                     |
          |                     |document.            |                     |




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          |---------------------+---------------------+---------------------|
          |Current law --       |Intent to defeat or  |Felony: each offense |
          |Revenue and Taxation |evade the reporting, |punishable by a fine |
          |Code � 7153.5.       |assessment, or       |of not less than     |
          |                     |payment of a tax or  |$5,000 and not more  |
          |                     |an amount due        |than $20,000, or     |
          |                     |required by law when |imprisonment for 16  |
          |                     |the amount of        |months, two years,   |
          |                     |unreported tax       |or three years, or   |
          |                     |liability aggregates |both the fine and    |
          |                     |at $25,000 or more   |imprisonment in the  |
          |                     |in any               |discretion of the    |
          |                     |12-consecutive-month |court.               |
          |                     |period.              |                     |
          |---------------------+---------------------+---------------------|
          |Current law --       |Fraud or an intent   |Civil penalty of 25  |
          |Revenue and Taxation |to evade existing    |percent of the       |
          |Code � 6485.         |tax laws.            |amount of any tax    |
          |                     |                     |deficiency.          |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |                     |                     |                     |
          |---------------------+---------------------+---------------------|
          |      Provision      |   Prohibited Act    |       Penalty       |
          |---------------------+---------------------+---------------------|
          |Current law -- the   |Knowingly or         |Misdemeanor:         |
          |"Fee Collection      |willfully files a    |punishable by a fine |
          |Procedures Law" --   |false return or      |of not less than     |
          |Revenue and Taxation |report with the      |$100 or more than    |
          |Code � 55362.        |board; refuses to    |$1,000, by           |
          |                     |permit the board or  |imprisonment in the  |
          |                     |any of its           |county jail for not  |
          |                     |authorized           |less than one month  |




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          |                     |representatives to   |or more than six     |
          |                     |make any inspection  |months, or by both.  |
          |                     |or examination for   |                     |
          |                     |which provision is   |                     |
          |                     |made in this part    |                     |
          |                     |(relating to         |                     |
          |                     |specified fees);     |                     |
          |                     |fails to keep any    |                     |
          |                     |records prescribed   |                     |
          |                     |by the board; fails  |                     |
          |                     |to preserve the      |                     |
          |                     |records for the      |                     |
          |                     |inspection of the    |                     |
          |                     |board for the time   |                     |
          |                     |that the board deems |                     |
          |                     |necessary; or        |                     |
          |                     |alters, cancels, or  |                     |
          |                     |obliterates entries  |                     |
          |                     |in the records for   |                     |
          |                     |the purpose of       |                     |
          |                     |falsifying the       |                     |
          |                     |records.             |                     |
          |---------------------+---------------------+---------------------|
          |Current law --       |Willfully evades or  |Felony:  jail        |
          |Revenue and Taxation |attempts in any      |felony, 16 months,   |
          |Code � 55363.        |manner to evade or   |two, or three years  |
          |                     |defeat the payment   |and a fine of not    |
          |                     |of specified fees.   |more than . . .      |
          |                     |                     |$5,000.              |
          |---------------------+---------------------+---------------------|
          |This bill -- as to   |Knowingly sells,     |Wobbler: misdemeanor |
          |sales and use tax    |purchases, installs, |penalty: fine of not |
          |(according to the    |transfers,           |more than $10,000,   |
          |sponsor).            |possesses, or uses   |imprisonment in a    |
          |                     |in this state any    |county jail for not  |
          |                     |automated sales      |more than one year;  |
          |                     |suppression device   |felony penalty: jail |
          |                     |or zapper or         |felony, 16 months,   |
          |                     |phantom-ware, as     |or two, or three     |
          |                     |defined.             |years, or by both    |




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                                                         AB 781 (Bocanegra)
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          |                     |                     |that fine and        |
          |                     |                     |imprisonment.        |
          |---------------------+---------------------+---------------------|
          |This bill -- as to   |Use an automated     |Liable for all       |
          |sales and use tax    |sales suppression    |taxes, interest, and |
          |(according to the    |device or zapper or  |penalties due as a   |
          |sponsor).            |phantom-ware.        |result of the use of |
          |                     |                     |that device.         |
          |---------------------+---------------------+---------------------|
          |This bill - as to    |knowingly sells,     |Wobbler:             |
          |specified fees       |purchases, installs, |misdemeanor penalty: |
          |(according to the    |transfers,           |a fine of not more   |
          |sponsor).            |possesses, or uses   |than $10,000, by     |
          |                     |in this state any    |imprisonment in a    |
          |                     |automated sales      |county jail for not  |
          |                     |suppression device   |more than one year;  |
          |                     |or zapper or         |Felony penalty: jail |
          |                     |phantom-ware.        |felony, 16 months,   |
          |                     |                     |or two, or three     |
          |                     |                     |years, or by both    |
          |                     |                     |that fine and        |
          |                     |                     |imprisonment.        |
          |                     |                     |                     |
          |---------------------+---------------------+---------------------|
          |      Provision      |   Prohibited Act    |Penalty              |
          |---------------------+---------------------+---------------------|
          |This bill - as to    |Bill uses an         |Liable for all       |
          |specified fees       |automated sales      |taxes, interest, and |
          |(according to the    |suppression device   |penalties due as a   |
          |sponsor).            |or zapper or         |result of the use of |
          |                     |phantom-ware.        |that device.         |
           ----------------------------------------------------------------- 
           
           Until the budget year 2002-2003, there was 170% in penalty  
          assessments applied on top of every fine, the current penalty  
          assessments are approximately 310% plus a flat fee of $79.  (See  
          Penal Code � 1464; Penal Code � 1465.7; Penal Code � 1465.8;  
          Government Code � 70373; Government Code � 7600.5; Government  
          Code � 76000 et seq; Government Code �76000.10; Government Code  
          � 76104.6; Government Code �76104.7.)  Thus, a $10,000 criminal  




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          fine under this bill would be $41,000.  

          Comment 7 below contains draft amendments agreed to by the  
          author which address these issues in a manner consistent with  
          the goals of the bill.  
           
          6.  Impact on Criminal Justice System - Incarceration

           The Assembly Appropriations Committee analysis of this bill  
          included the following, concerning the potential impact of this  
          bill on custodial facilities:

               Unknown, probably minor nonreimbursable local law  
               enforcement and incarceration costs, offset to a  
               degree by increased fine revenue and offender  
               financial liability.

               It is not likely many offenders would serve actual  
               jail time under this bill.  By creating an alternate  
               felony/misdemeanor, however, the bill does create the  
               possibility of longer jail terms that could impact  
               future realignment formulae and exacerbate jail  
               overcrowding.  

          7.  Draft Amendments

           The following mock-up reflects amendments to be offered in  
          Committee by the author which would address the issues raised  
          above:

               SECTION 1.  Section 7153.6 is added to the Revenue and  
               Taxation Code, to read:

               7153.6. (a)  Notwithstanding any other provision of  
               this part, any person who purchases, installs or uses  
               in this state any automated sales suppression device  
               or zapper or phantom-ware with the intent to defeat or  
               evade the determination of an amount due required by  
               law to be made is guilty of a misdemeanor. 
                




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               (b)   Notwithstanding any other provision of this part,  
               a    Any  person who  , for commercial gain,    knowingly   
               sells, purchases, installs, transfers,  or  possesses  ,  
               or uses  in this state any automated sales suppression  
               device or zapper or phantom-ware  with the knowledge  
               that the sole purpose of the device is to defeat or  
               evade the determination of an amount due required by  
               law to be made  is guilty of an offense punishable by a  
               fine  as specified in paragraphs (1) and (2)    of not  
               more than ten thousand dollars ($10,000)  , by  
               imprisonment in a county jail for not more than one  
               year, or, pursuant to subdivision (h) of Section 1170  
               of the Penal Code, for 16 months, or two, or three  
               years, or by both that fine and imprisonment. In  
               addition, any person who uses an automated sales  
               suppression device or zapper or phantom-ware shall be  
               liable for all taxes, interest, and penalties due as a  
               result of the use of that device. 


























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                   1.        Where a person is guilty of the offense  
                    described in subdivision (b) and he or she sold,  
                    installed, transferred, or possessed three or  
                    fewer automated sales suppression devices or  
                    zappers or phantom-ware, they shall be punished  
                    by a fine of not more than $5,000.
                  2.        Where a person is guilty of the offense  
                    described in subdivision (b) and he or she sold,  
                    installed, transferred, or possessed more than  
                    three automated sales suppression devices or  
                    zappers or phantom-ware, they shall be punished  
                    by a fine of not more than $10,000.
                
               (  b   c  )  For purposes of this section: . . . (no  
               amendments to this subdivision)

                (d)         This section shall not preclude prosecution  
               under any other law.
                
               SEC. 2.  Section 55363.5 is added to the Revenue and  
               Taxation Code, to read:

               55363.5. 

               (a)  Notwithstanding any other provision of this part,  
               any person who purchases, installs or uses in this  
               state any automated sales suppression device or zapper  
               or phantom-ware with the intent to defeat or evade the  
               determination of an amount due required by law to be  
               made is guilty of a misdemeanor. 
                
               (b)   Notwithstanding any other provision of this part,  
               a   Any  person who  , for commercial gain,    knowingly   
               sells, purchases, installs, transfers,  or  possesses  ,  
               or uses  in this state any automated sales suppression  
               device or zapper or phantom-ware  with the knowledge  
               that the sole purpose of the device is to defeat or  
               evade the determination of an amount due required by  
               law to be made  is guilty of an offense punishable by  




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               a fine  as specified in paragraphs (1) and (2)   of not  
               more than ten thousand dollars ($10,000)  , by  
               imprisonment in a county jail for not more than one  
               year, or, pursuant to subdivision (h) of Section 1170  
               of the Penal Code, for 16 months, or two, or three  
               years, or by both that fine and imprisonment. In  
               addition, any person who uses an automated sales  
               suppression device or zapper or phantom-ware shall be  
               liable for all taxes, interest, and penalties due as a  
               result of the use of that device.

                   1.        Where a person is guilty of the offense  
                    described in subdivision (b) and he or she sold,  
                    installed, transferred, or possessed three or  
                    fewer automated sales suppression devices or  
                    zappers or phantom-ware, they shall be punished  
                    by a fine of not more than $5,000.
                  2.        Where a person is guilty of the offense  
                    described in subdivision (b) and he or she sold,  
                    installed, transferred, or possessed more than  
                    three automated sales suppression devices or  
                    zappers or phantom-ware, they shall be punished  
                    by a fine of not more than $10,000.
                
               (  b   c  ) For purposes of this section: . . .  (no  
               amendments to this subdivision)
                
                (d)         This section shall not preclude prosecution  
               under any other law.
           

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