Farrar

Revenue and Taxation Code section 19055 provides that an administrative claim for refund of income taxes when “filed for or on behalf of a class of taxpayers shall do all of the following: [ft] (a) Be accompanied by written authorization from each taxpayer sought to be included in the . class, [ftl (b) Be signed by each taxpayer or taxpayer’s authorized representative. [ft (c) State the specific grounds on which the claim is founded.”

This appeal from an order refusing to certify a class action seeking a judicial refund of taxes collected by the Franchise Tax Board (Board) presents the issue of whether section 19055 means what it says. We hold that it does and that it is to be enforced on that basis. We further hold that would-be representatives who fail to take section 19055 at face value cannot invoke the doctrine of substantial compliance otherwise applicable to class actions.

Background

In a very real sense, it all began with Sandra Brown. It was she who in the early 1980’s instituted a class action for refund of income taxes the Board had assessed and collected on dividends paid to class members by a trio of mutual funds for the tax years 1978, 1979, 1980, and…