California taxpayers often focus on whether they overpaid tax. That is understandable, but in a refund dispute, being right on the numbers is not always enough. If the refund claim is filed too late, the California Franchise Tax Board may deny the claim without ever reaching the merits.

Recent California Office of Tax Appeals opinions reinforce that point. OTA’s June 2026 franchise and income tax opinions include J. Lord and D. Lord, 2026-OTA-304, a nonprecedential decision involving the statute of limitations on a claim for refund under Revenue and Taxation Code section 19306. OTA’s June 2026 list also includes many other refund statute cases, showing that missed refund deadlines remain a recurring problem in California tax controversy.

The National Taxpayer Advocate’s Fiscal Year 2027 Objectives Report to Congress offers a mixed picture of the 2026 filing season. For many taxpayers, the IRS filing season worked as intended. Returns were processed, refunds were issued, and electronic systems handled a large volume of filings.

But the report also highlights a serious problem for taxpayers whose cases do not move smoothly through automated processing. When a return is suspended, a refund is delayed, identity theft is suspected, a notice is unclear, or a taxpayer needs human assistance, the experience can become frustrating, slow, and financially disruptive.

The California Office of Tax Appeals has posted its current opinion-cycle notice, reminding taxpayers and practitioners that comments on whether opinions posted on June 1 should or should not be designated as precedential are due by June 29. OTA also states that new opinions will be posted on July 6.

For many taxpayers, this may sound like a narrow administrative update. It is not. OTA opinions can shape how California tax disputes are decided, especially when an opinion becomes precedential. Businesses, individuals, tax professionals, and taxpayers with pending California appeals should understand why these opinion cycles matter.

The IRS’s 2025 Data Book shows a tax agency under pressure. The IRS still processed hundreds of millions of returns and collected trillions of dollars, but audit closures and recommended additional tax declined from the prior year. At the same time, staffing reductions and operational strain may affect how quickly the IRS handles audits, notices, refunds, identity-theft cases, correspondence, and appeals.

For taxpayers, the practical lesson is not that IRS enforcement has disappeared. It has not. The lesson is more nuanced: IRS enforcement may become less predictable, more automated in some areas, more selective in others, and slower when human review is required.

That combination can be difficult for taxpayers. A lower audit rate does not necessarily mean a lower risk of IRS contact. It may mean fewer traditional audits, more document-matching notices, longer response times, delayed resolutions, and greater importance placed on records, transcripts, and procedural deadlines.

The IRS has announced a new time-limited settlement opportunity for eligible partnerships involved in syndicated conservation easement and historic preservation easement disputes. For investors still involved in these cases, the offer deserves careful review.

Artificial intelligence is no longer a distant technology issue for lawyers, accountants, and tax professionals. It is already being used to summarize documents, draft correspondence, organize facts, analyze regulations, and speed up research. Used carefully, AI can help professionals work more efficiently. Used carelessly, it can create serious risks: inaccurate advice, fabricated citations, disclosure of confidential information, improper billing, and professional discipline.

California’s Franchise Tax Board recently highlighted an important conformity update for tax-exempt organizations. In its June 2026 Tax News, FTB explained that Senate Bill 711 updated California’s conformity to Internal Revenue Code section 512 as of January 1, 2025, subject to California-specific modifications.

For California nonprofits and other exempt organizations, this matters because California is now aligning more closely with the federal rules requiring separate reporting of unrelated business taxable income, commonly referred to as UBTI, for each unrelated trade or business under IRC section 512(a)(6).

This is not merely a form change. It may require exempt organizations to revisit how they identify unrelated business activities, track revenue and expenses, allocate shared costs, preserve net operating loss information, and prepare for future California reporting requirements.

Form 843, Claim for Refund and Request for Abatement, is one of the principal tools taxpayers use to request a refund or abatement of certain penalties, additions to tax, interest, fees, or other amounts. But Form 843 is not just a form. The form itself is only the cover page. The substance of the request is usually the narrative: the factual chronology, legal basis, supporting documents, and explanation of why the IRS should remove or refund the amount at issue.