Polk

BACKGROUND

In each of the relevant tax years, plaintiff lived and was employed in California. In 2015, she earned a combined $105,430 from Warner Bros. Entertainment, Inc. and New Line Productions, Inc. In 2016, she earned about $110,000 from New Line Productions, Inc. She also received distributions reported on Internal Revenue Service forms 1099-R exceeding $20,000. In 2018, she earned about $215,245 from WB Studio Enterprises, Inc. Each of her employers withheld state taxes from her paychecks, and all these income sources reported her income to the state. Despite receiving this income, plaintiff failed to fully report it on her state income tax returns. She reported no tax liability for any of the relevant tax years and claimed a refund for all amounts of state income tax withheld. FTB disagreed with plaintiff’s calculation of her income tax liability for each of the relevant tax years. In April 2022, it mailed a notice of proposed assessment (NPA) to plaintiff proposing a $10,846.41 additional tax, penalty and interest assessment for the 2015 tax year. Plaintiff did not protest the assessment. Accordingly, in August 2022 FTB mailed a state income tax balance due notice (tax…