In January, the Board of Equalization heard proposals on proposed changes to 
statistical sampling methods outlined in Chapter 13 of the Audit Manual.  We were 
alerted to the potential revenue losses that could occur if these proposed changes 
were to be adopted.  Thankfully,  the Business Taxes Committee recognized our concern 
in January and delayed action so we could have addition time to review and comment.  
It is now time for you to act.

If you attended the Legislative Seminar last week, you heard David Jones warn that 
administrative actions taken by the BOE could prove far more dangerous to city 
revenues than recent legislation.  This is a case in point.  If a "de minimis" 
standard is used sophisticated taxpayers could ostensibly underpay taxes by up to one 
percent without any consequences.  The attached letter outlines concerns cities and 
the state should have over this potential threat to revenues.  Please take time to 
personalize the letter and submit it to the BOE.  We understand the matter will again 
be taken up by the committee at a July or August meeting.

Thank you.

Frances Medema
Policy Analyst
League of California Cities
1400 K Street Suite 400
Sacramento, CA 95814
phone: 916/658-8218
fax:       916/658-8240
email:    [EMAIL PROTECTED]

BOECH13.doc

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