Approximately 36 percent of the appeals cases that were closed by the Office of Tax Appeals in 2025 were closed because the Franchise Tax Board or California Department of Tax and Fee Administration withdrew its objection, according to the latest statistics from the OTA.
The tax agency withdrawals account for more case closures than any other single reason. The other reasons for closing a case were, in order: “non-appeal/no jurisdictional notice” (27 percent), administrative law judges issued a decision based upon the written record (15 percent), appeal was withdrawn by the taxpayer (8 percent), “other” (6 percent), appeal was determined to have been filed too late (5 percent), and the administrative law judges issued a decision after an oral hearing (4 percent).
Other statistics from the OTA:
- There were 236 business tax appeals and 3,171 franchise and income tax appeals in 2025, compared to 274 and 2,800, respectively, in 2024. The number of franchise and income tax appeals has grown from roughly 1,200 a year from 2018 to 2020. The number of business tax appeals has ranged from a low of 116 in 2021 to a high of 300 in 2018, and has hovered near 250 for the past three years.
- The OTA opens an average of 237 cases per month, and closes an average of 233.
- Virtual hearings continue to be the most popular choice for oral hearings – 79 in 2025, compared to 35 hearings at the OTA venue in Cerritos, 10 in Sacramento, and fewer than five in Fresno.
- The OTA issued 568 written opinions in 2025, down from 630 in 2024, but up from the numbers in all other years.
The statistics were included in a report titled “OTA by the Numbers,” prepared by Claudia Lopez, deputy director of the Case Management Division, and other OTA staff for a presentation to the OTA Advisory Committee.