BILL ANALYSIS
SENATE REVENUE & TAXATION COMMITTEE
Senator Lois Wolk, Chair
SB 1133 - Runner
As Amended: April 7, 2010
Hearing: April 14, 2010 Fiscal: Yes
SUMMARY: Abolishes FTB, and Tax Collection Functions of
the Department of Insurance and Employment
Development Department; Consolidates These
Functions into the State Board of Equalization.
EXISTING LAW (California Constitution and Statute),
establishes the BOE as a five-member board composed of four
members elected by each district plus the State Controller.
BOE administers sales and use taxes, excise taxes, special
taxes, and the state's fee programs. BOE also values
property of statewide assessees and sets rules for County
Assessors - its initial function was to "equalize"
assessment practices between counties when it was created
in 1870. Additionally, BOE adjudicates income tax appeals
after exhausting FTB administrative dispute process; if the
BOE denies the appeal, the taxpayer may bring an action in
state court. Only the BOE's property tax duties are
enshrined in the Constitution; all of its other powers are
statutory.
EXISTING LAW creates the Franchise Tax Board (FTB) as
a three-person board comprised of the State Controller,
Director of the Department of Finance, and Chair of the
BOE. FTB administers the Personal Income Tax and
Corporation Tax Law, and collects debts on behalf of state
and local agencies.
SB 1133 - Runner Page 11
EXISTING LAW directs the California Employment
Development Department (EDD) to administer the Unemployment
Insurance Fund, the Disability Insurance Fund, and the
Employment Training Fund. Employers withhold from
employees, and send the proceeds to EDD along with the
insurance premiums. EDD also maintains employment records
and implements several federal job-training programs.
EXISTING LAW vests with the Department of Insurance
(DOI) the responsibility to administer and collect the
Gross Premiums Tax.
THIS BILL abolishes the FTB, and places its duties and
responsibilities with the BOE. The measure provides that
the BOE shall continue as a party to any action in which
FTB is currently involved on January 1, 2012.
THIS BILL places the tax administration functions of
the EDD and DOI in BOE, and similarly replaces BOE
successor to those agencies in any action on January 1,
2012.
THIS BILL provides that BOE substitutes for FTB, EDD,
and DOI in all statutes, laws, rules, or regulations
currently in force, vests all powers of those agencies into
BOE, and provides that those laws are expressly continued
in force.
THIS BILL states that the executive director of the
BOE, with the approval of the members, shall organize the
new responsibilities transferred from the three other
agencies as he or she deems necessary for the proper
conduct of the consolidated revenue collection,
administration, and enforcement actions. The measure also
transfers civil service staff from the other entities to
BOE. SB 1133 states that no contract, lease, license, or
any other agreement entered into by the other entities
shall be void or voidable because of the bill. On January
1, 2012 the bill provides that unencumbered balances of
money from the other three entities shall be available to
BOE. On that date, the other three entities shall transfer
all relevant books, documents, records, and property to
BOE.
SB 1133 - Runner Page 11
THIS BILL makes findings and declarations regarding
the desire of the Legislature to consolidate and streamline
the functions currently performed by these entities.
THIS BILL requires BOE to report to the Legislature
regarding its plan for an progress of BOE's assumption of
the duties of the other agencies, including recommendations
for legislation to effectively achieve efficiencies of
purposes intended by the bill, including a strategic plan
for consolidation of computer systems, telecommunications,
and office space of the other agencies, identification of
functions readily conducive to consolidation or
centralization, and identification of administrative
functions because of conflicts or inconsistent
administrative processes cannot be readily consolidated
into the board.
FISCAL EFFECT:
According to the FTB: "Consolidating the FTB with the
BOE would provide opportunities to increase efficiency and
effectiveness over the long term; however, the magnitude of
impact is unknown and would be realized over time.
Potential benefits would be offset by the costs associated
with merging the organizations and systems, particularly in
the short-term. The magnitude of the benefits and costs
would depend on the degree to which the departments'
functions and systems are integrated as a result of
consolidation. In addition, working through the
organizational, technology, and other issues associated
with merging the FTB into the BOE and with the BOE assuming
the tax administrative responsibilities of the EDD and the
Department of Insurance could divert resources from core
revenue-generating functions.
An accurate cost analysis of consolidation would
require input from the other affected departments to
analyze each function and process each such department
performs in comparison to functions and processes performed
by the BOE. Accordingly, the department's costs to
administer this bill cannot be determined at this time.
SB 1133 - Runner Page 11
The department will continue to analyze consolidation and
its potential fiscal impacts as this bill moves through the
legislative process. "
According to the BOE, "According to the LAO's January
2005 report, a potential long-term savings exists
associated with the partial physical consolidation of the
agencies' payment and document processing activities by
reducing duplication, streamlining staffing, and making
more efficient use of existing capital.
However, the LAO points out that these savings are
likely to be achievable only through an up-front investment
by the state in additional systems that allow the agencies'
separate and distinct processes to function in a
consolidated fashion. In addition, given that the agencies
are at different levels of technological advancement, the
LAO report notes that considerable additional investment
may be necessary to avoid losing the technological edge
that some agencies have achieved in their processing
functions.
The amount of these savings could not be determined
without an extensive, detailed study.
This bill in and of itself would not affect the
state's tax revenues. In general, the transfer of the tax
collection and administration responsibilities of the FTB,
EDD and CDI to the BOE would not appear to have any effect
on the state's revenues. It is possible, however, that a
decrease in revenue could be experienced during the period
of conversion as a result of the requirement to spend staff
time developing the procedures for the new agency.
COMMENTS:
A. Purpose of the Bill
SB 1133 - Runner Page 11
California's tax collection system is currently
divided among four different agencies: The Board of
Equalization (BOE) administers the State's sales tax,
state-assessed property taxes and a variety of excise
taxes; the Franchise Tax Board (FTB) collects state income
taxes; the Department of Motor Vehicles (DMV) collects
motor vehicle-related fee; and the Employment Development
Department (EDD) collects employment taxes.
FTB administers the Personal Income Tax Law (PITL) and
Corporation Tax Law (CTL). Board members consist of the
State Controller, Director of the Department of Finance,
and the Chair of the Board of Equalization.
The BOE is an independent constitutional body that is
an agency-equivalent and not under the jurisdiction of the
Governor. The BOE administers property tax, sales and use
tax, the tax appellate program, and special taxes including
fuel tax, excise tax, environmental fees, and electronic
waste recycling fee.
Because California's tax revenue collection
agencies-BOE and FTB-perform many of the same functions,
they should be should be consolidated into the State Board
of Equalization.
B. Come Together
This chart briefly describes seven options that have
been associated with consolidation in the past.
------------------------------------------------------------
|Option |Source |Fiscal Impact |Analysis |
| | | | |
|--------------+----------+-----------------+----------------|
SB 1133 - Runner Page 11
|BOE & FTB |LAO, 1994 |Reduced expenses |LAO argued that |
|merge | |in the long run; |consolidation |
|functions; | |significant |enhanced |
|BOE retains | |initial start up |accountability |
|tax appeal | |costs. Little |and decreased |
|function | |Hoover estimated |taxpayer |
| | |$50 million |confusion. |
| | |savings in 1994 |Direction and |
| | | |implementation |
| | | |from the |
| | | |executive |
| | | |branch would be |
| | | |clearer. |
| | | | |
|--------------+----------+-----------------+----------------|
|Create |California|Planning, |Again, |
|Department of | |budgeting |consolidation |
|Revenue. |Constituti|functions |could enhance |
|Eliminate FTB |onal |consolidated as |accountability |
|& BOE |Revision |above. Unknown |and create "one |
|(including |Commission|impact from |stop shop" for |
|tax appeal |. |removing tax |taxpayers. |
|functions) |Various |appeals function |There is lots |
|and combine |Bills<1> |from BOE. |of disagreement |
|with EDD | |Eliminating BOE |on the |
| | |requires a |appropriate |
| | |Constitutional |location for |
| | |amendment. |the tax appeals |
| | | |functions: BOE, |
| | | |Department of |
| | | |Revenue or Tax |
| | | |Court. |
| | | | |
|--------------+----------+-----------------+----------------|
|Create |Governor |Potentially |This option |
|California |Wilson, |reduced expenses |retains the BOE |
|Tax |1994. |in the long run |and creates a |
|Commission: |California|but large |Commission but |
|Eliminate | |upfront |it is unclear |
|FTB, combine |Performanc|consolidation |who serves on |
------------------------
<1> California Constitutional Revision Commission (1996);
SB 87/SCA 5 (Kopp, 1994), SB 1727/SCA 9 (Kopp, 1995), SCA
39 (Killea, 1996), and AB 2794 (Bowen, 1996).
SB 1133 - Runner Page 11
|with DMV and |e Review, |costs. |the commission |
|EDD. |2007. | |and whether the |
| |Various | |BOE or the |
| |Bills<2> | |Governor would |
| | | |be the umbrella |
| | | |organization. |
| | | | |
|--------------+----------+-----------------+----------------|
|Eliminate FTB |Various |Same as above; |This option |
|and |Bills<3> |unknown impact |combines the |
|consolidate | |from eliminating |two largest tax |
|into BOE or | |BOE |entities in the |
|eliminate BOE | | |state; one |
|and | | |retains the |
|consolidate | | |Governor as the |
|into FTB | | |executive; the |
| | | |other makes BOE |
| | | |responsible for |
| | | |all taxes in |
| | | |the state. |
| | | | |
|--------------+----------+-----------------+----------------|
|Tax Court |Various |Unknown |Tax Courts in |
| |Bills<4> | |other states |
| | | |apply a |
| | | |precedent-based |
------------------------
<2> Without EDD and DMV: AB1996/ACA 39 (Harris) and SB 1695
(Kopp, 1992) created a consolidated Department of Revenue
and a Tax Commission, see also ACA 13 (Leonard, 2001), ACA
22 (Dutra, 2003), ACA 14 (DeVore, 2005))
<3> SB 1052/SCA 22 (Alquist), AB 3338 (McClintock, 1992),
AB 15
(Klehs, 1993), AB 2000 (Dutton, 2003), SB 216 (Dutton,
2005), and SB 274 (Dutton, 2007).
<4> SB 1395 (Kopp, Ayala, et al, 1989), SB 23/SCA 25 (Kopp,
1991),
SB 87/SCA 5 (Kopp, 1993) eliminated BOE and FTB and
replaced with Department of Revenue and Tax Court, also SB
1424 (Burton, 2004) and AB 2472 (Wolk, 2004).
SB 1133 - Runner Page 11
| | | |objective legal |
| | | |forum for |
| | | |adjudicating |
| | | |tax cases; |
| | | |judges selected |
| | | |based on tax |
| | | |law expertise. |
| | | | |
|--------------+----------+-----------------+----------------|
|Consolidate |Various |CPR estimating a |LAO projects |
|cashiering |Bills<5> |savings of |medium to long |
|functions | |approximately |term savings |
|only | |$20 million per |contingent on |
| | |year |initial costs |
| | | |to fund |
| | | |upgrades in the |
| | | |new systems. |
| | | |Partial |
| | | |consolidation |
| | | |would have to |
| | | |precede full |
| | | |consolidation |
| | | |of functions. |
| | | | |
------------------------------------------------------------
According to FTB, this table shows the positions and
funding for each agency, although the table does not show
which employees administer taxes, and would be affected by
the bill:
---------------------------------------------------
| | Positions | Funding, in |
| | | millions |
| | | |
------------------------
<5> LAO (2005) resulting from study required by AB 986
(Horton),
California Performance Review (2007); SB 956 (Rosenthal,
1997), SB 896 (Speier, 1999) transferred DOI revenue
collection functions to BOE.
SB 1133 - Runner Page 11
|-----------+------------------+--------------------|
|BOE | 4,033 | $428 |
| | | |
|-----------+------------------+--------------------|
|FTB | 5,336 | $537 |
| | | |
|-----------+------------------+--------------------|
|CDI | 1,304 | $227 |
| | | |
|-----------+------------------+--------------------|
|EDD | 8,739 |$111 |
| | | |
---------------------------------------------------
C. Of Holes and Digging
The Legislative Analyst's office, and department
analyses have consistently argued that tax agency
consolidation will incur significant immediate costs to
implement, but could yield long-term savings. Whether
long-term savings will offset those immediate costs is
largely unknown. The LAO summarized the findings of its
report released January 10, 2005, as follows:
Consolidation of the tax agencies' payment and
documentation processing activities could in the
medium to long term generate some annual cost savings
and interest earnings through elimination of
duplicative functions and increased efficiencies. The
state, however, would have to incur significant net
costs in the short term to achieve these savings. In
addition, such benefits are likely to be less than
benefits from increasing electronic processing. We
therefore recommend that low priority be given to
consolidation of payment and document processing
functions in favor of steps to increase electronic
processing.
Tax agency consolidation doesn't eliminate any taxes
or tax programs; each one would still be administered, only
from a different agency. It is unclear whether
consolidating staff and resources together results in
SB 1133 - Runner Page 11
tangible savings to the state. Instead, the initial costs,
and the difficulty ensuring that promised savings are
realized, could render consolidation more costly than
maintaining the current structure.
D. Ghosts of Consolidations Past
On June 10, 2009, the Committee heard the Department of
Finance's proposal for tax agency consolidation. The
Committee Chair's recommendation to the Budget Committee
stated:
BOE and FTB both need to upgrade key components of
their information technology systems, which each
agency now operates independently. Additionally, the
situation with the BOE building which houses its
workers is untenable. Any significant future
acquisitions of information technology systems or
physical infrastructure should serve both BOE and FTB,
and possibly integrate with EDD systems, which are
currently considered superior. The Committee
recommends that to the maximum extent practicable, any
acquisitions of property or information technology
should serve both agencies, and BOE should move
employees from the BOE building to the FTB campus,
especially those employees who can help enhance
economies of scale for the revenue system by being
housed together.
Additionally, the Department of Motor Vehicles'
(DMV) vehicle license and registration collection
functions should be included in consolidation efforts.
DMV should immediately join the three-agency task
force which currently includes FTB, BOE and EDD.
The four agencies, FTB, BOE, EDD and DMV, should
immediately begin working on a technology that
incorporates a single taxpayer identification number.
With a single number, there would be greater
SB 1133 - Runner Page 11
information sharing and ultimately greater tax
compliance which will result in increased revenues.
The issue of governance is inextricably intertwined
with any consideration of consolidation. The
Administration's proposal consolidates the tax policy
elements of FTB and BOE away from its existing
governing boards to a Department of Revenue, led by a
Gubernatorial-appointed, Senate-confirmed executive
director. Shifting tax policy regulatory authority
and oversight under the Governor will inevitably bear
different tax policy results, and presents risks of
executive interference in tax cases. FTB is widely
considered one of the world's most innovative and
respected revenue-collection agencies in the world;
its record does not merit removing its authority over
tax policy and assigning it to the Governor. The
Committee recommends deferring discussion over
governance of the tax system because of the
substantive issues involved, and that issues regarding
governance do not have a current, measurable fiscal
impact.
The administration similarly recommends
consolidating audit functions immediately to realize
economies of scale and better deploy existing audit
resources, and claims savings in the 2010-11 fiscal
year. In concept, the Committee endorses this plan.
For now, the committee recommends that the agencies
create the single taxpayer identification number as
discussed above.
As to the major recommendation of the Governor,
which is a new Department of Revenue, the LAO suggests
that consolidating the agencies might accelerate the
process of coordination. I will work with the LAO and
the Department of Finance to further refine this
proposal which I support in concept
SB 1133 - Runner Page 11
E. Blowing Up Boxes
The Department of Finance's Department of Revenue
proposal:
Statutorily recasts the Franchise Tax Board (FTB)
and portions of the Board of Equalization and the
Employment Development Department as the Department of
Revenue (DOR).
Eliminates the three-member Franchise Tax Board,
and vest responsibility for DOR management in the FTB
Executive Director, who will be re-titled the
Secretary of Revenue. The Secretary will have cabinet
status. The DOR Secretary shall be appointed by
Governor and serve at the Governor's pleasure.
Appointment shall be subject to Senate confirmation.
All 5,200 current FTB positions and approximately $557
million would transfer to the new department.
Statutorily transfers the tax collection functions
of the Employment Development Department (EDD) to the
DOR, along with approximately 1,540 personnel $153
million
Statutorily transfers all elements of the Board of
Equalization (BOE), except for the property
tax-related functions and Board tax appeal functions,
to the Department of Revenue along with all attendant
personnel and resources. Board of Equalization would
retain approximately 200 positions and $22 million and
the other 4,000 positions and $422 million would
transfer to Department of Revenue.
Initially, designated organizational units and all
incumbent staff transfers to the personnel and
operational control of the new department on January
1, 2010. Funding transfers to the new department
pursuant to the determination of the Director of
Finance under Sec. 16304.9 of the Government Code. It
SB 1133 - Runner Page 11
is expected that the department will contract back
with EDD and BOE for some time to operate the
divisions that are transferring to the Department of
Revenue.
Provides that the Secretary shall report to the
Governor and the Director of Finance on plans to
consolidate the operations of the functions including
facilities, information technology, records, audit and
collection functions, administrative support, payment
processing, and taxpayer relations. The plans would
be implemented through the budget process, Sec.
16304.9, and legislation. Through this process
appropriate support staff and resources will be
shifted from EDD and BOE to the DOR.
It is expected that the DOR takes responsibility as
the tenant for the BOE HQ building as soon as
practicable and that remaining BOE staff will move
out. It is envisioned that the sale, rehabilitation,
transfer to other state tenants, or other disposition
of the building will be incorporated into the plan for
facilities which will likely include a large new
building at the FTB campus.
Statutorily requires the BOE and the EDD to render
the DOR all assistance the DOR Director may request in
effectuating the transfer of responsibilities.
Opportunities to get savings and avoid costs exists
in consolidating payment processing (a small
consolidation of EDD and BOE processing is included in
the May Revision).replacement of legacy IT systems at
both FTB and BOE, consolidating tax payer records and
identifications (especially businesses), consolidated
business auditing, filing enforcement and collections
activities including the reallocation of resources to
the highest marginal recovery activities throughout
all of the General Fund revenue sources, consolidated
SB 1133 - Runner Page 11
administrative services, consolidated tax payer
contact resources.
Leverages strong management at FTB over more tax
collection programs, especially in the IT area. Now
that the Statewide Child Support System has
effectively been completed and shifted to the
Department of Child Support Enforcement, FTB is ready
to start major IT development projects. BOE is also
looking to start major IT development efforts.
--------------------------------------------------------------
| Preliminary Budget Estimates for Department of Revenue |
| |
|--------------------------------------------------------------|
| (Dollars in Thousands) |
| |
--------------------------------------------------------------
|-------------------------+------+------+------+-------+------|
| |Positi|Person|Operat| Total |Genera|
| | ons | al | ing | Funds | l |
| | |Servic|Expens| | Fund |
| | | es | es | | |
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Shift to Department of | | | | | |
|Revenue | | | | | |
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Franchise Tax Board | 5,224|$421,6|$135,8|$557,49|$521,6|
| | | 49| 45| 4| 32|
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Board of Equalization | 3,991|326,00|96,000|422,000|234,00|
| | | 0| | | 0|
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Employment Development | 1,539|122,30|30,900|153,200|25,500|
| | | 0| | | |
SB 1133 - Runner Page 11
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Total |10,754|$869,9|$262,7|$1,132,|$781,1|
| | | 49| 45| 694| 32|
| | | | | | |
|-------------------------+------+------+------+-------+------|
| | | | | | |
| | | | | | |
|-------------------------+------+------+------+-------+------|
|Remain at Board of | 196|$16,00|$5,900|$21,900|$21,90|
|Equalization | | 0| | | 0|
| | | | | | |
-------------------------------------------------------------
|Remain at Employment | 7,799|$607,4|$236,3|$843,70|$6,800|
|Development | | 00| 00| 0| |
| | | | | | |
|-------------------------+------+------+------+-------+------|
| | | | | | |
| | | | | | |
-------------------------------------------------------------
--------------------------------------------------------------
| Major Revenues Collected by Department of Revenue |
| |
|--------------------------------------------------------------|
| (Dollars in Millions) |
| |
--------------------------------------------------------------
-------------------------------------------------------------
|Personal Income Tax | | | |$49,542|$48,83|
| | | | | | 6|
| | | | | | |
-------------------------------------------------------------
|Corporation Tax | | | | $8,799|$8,799|
| | | | | | |
| | | | | | |
-------------------------------------------------------------
|Sales and Use Tax | | | |$44,177|$27,58|
| | | | | | 3|
| | | | | | |
-------------------------------------------------------------
|Fuel Taxes | | | | $3,145| $0|
| | | | | | |
|-------------------------+------+------+------+-------+------|
SB 1133 - Runner Page 11
|Cigarette and Tobacco | | | | $937|$102 |
| | | | | | |
| | | | | | |
| | | | | | |
-------------------------------------------------------------
F. Current Tax Appeals in California
Currently in California, a state agency, FTB,
administers the personal income tax and corporation tax
laws according to the federal and state Constitution and
statutes. Disputes are resolved by the BOE, the only panel
of its kind in the country where elected officials
determine the merits of tax cases. The FTB, usually after
an audit or an IRS adjustment, issues a notice of proposed
assessment ("NPA"). If the taxpayer files a protest with
FTB, the NPA does not "go final." If no is protest if
filed, the NPA "goes final" and collection commences. The
taxpayer can pay the tax in full and file a claim for
refund. If FTB denies the claim, the taxpayer can appeal
the denial to the BOE. Briefs are filed with the BOE and
the case can be heard for about 40 minutes by the full
five-member board. If the taxpayer wins, that's it. If
the taxpayer loses, the taxpayer can file a refund action
in Superior Court.
If the taxpayer files a protest with FTB, a protest
hearing is held. If the FTB does not decide in favor of
the taxpayer, the taxpayer may file an appeal with the BOE.
Briefs are filed with the BOE and a 40-minute hearing
before the full five-member board can be requested. If the
board decides in favor of the taxpayer, that's it. If the
board decides against the taxpayer, the NPA goes final and
collection commences. The taxpayer may pay the tax in full
and file a claim for refund with the FTB. If FTB denies
the claim, the taxpayer may file an appeal of the denial of
the claim with the BOE. The taxpayer has a right to a
hearing before the full five-member BOE, but unless
something has changed the BOE will not change its position.
The taxpayer may then file a refund action in Superior
Court
SB 1133 - Runner Page 11
SB 1133 consolidates FTB into BOE, merging the
administrative body and the appellate body into one entity
under the direction of elected officials independent of the
Governor or the Legislature. BOE would administer taxes,
set regulations, hear appeals, and be the last stop if the
state loses upon appeal - a model quite different from
other states and the federal system, where an independent
tax court resolves disputes between taxpayers and the IRS
on a post-payment basis, and District courts can resolve
cases prior to payment. Taxpayers could argue that they
are not being afforded substantive due process rights under
the U.S. Constitution because they would be afforded no
prepayment appeal to an independent body, which the current
system affords taxpayers.
G. Ghosts of Consolidation Past, Part Deux
One of the primary issues when considering tax agency
consolidations measures is governance, as identified by the
Committee in its evaluation of the Governor's proposal.
Consolidation may be thought of as a cost-saving measure,
but while those impacts are largely unresolved, SB 1133
would reshuffle the powers of running the tax system.
Consolidating the state's taxing functions powers into BOE
will cause tension with the Legislature and the Governor as
tax policy values differ as their compositions change as it
enacts regulations and resolves appeals. This issue was
cited by Governor Pete Wilson, who vetoed the only effort
to consolidate agencies that ever reached the Governor's
Desk (AB 15, Klehs, 1993), stating:
"To the Members of the California Assembly:
I am returning Assembly Bill No. 15 without my
signature.
This bill would abolish the Franchise Tax Board (FTB)
and would provide for the transfer of its powers and
duties to the State Board of Equalization operative
January 1, 1996.
SB 1133 - Runner Page 11
AB 15 would centralize all state tax policy,
implementation, and administration outside the
executive branch of government. This makes no sense.
Ultimately, the Governor is held accountable for the
operations of state government, including the tax
system, and should be.
In contrast, most other state revenue departments are
administered by a director appointed by the Governor,
and confirmed by the state Senate.
I support streamlining government and consolidating
the Board of Equalization and the Franchise Tax Board.
AB 15 is not the way to accomplish this purpose. The
Administration sponsored legislation that would have
created a Department of Revenue within the
Administration. That approach would avoid the
conflict of interest inherent in AB 15, in which the
Board of Equalization serves as both administrator of
the tax system, as well as the appellate body for
taxpayer appeals."
Support and Opposition
Support: Howard Jarvis
Taxpayers Association
Oppose:American Federation of State, County, and
Municipal Employees
California Tax Reform Association
---------------------------------
Consultant: Colin Grinnell
SB 1133 - Runner Page 11