Revenue and Taxation Code section 19547

In a matter involving tax administration under this part, a return or return information shall be open to inspection by the Attorney General or other legal representatives of the state, if any of the following apply:

(a)

The taxpayer is or may be a party to the proceeding, or the proceeding arose out of, or in connection with, determining the taxpayer’s civil or criminal liability, or the collection of the taxpayer’s civil liability with respect to any tax imposed under Part 10 (commencing with Section 17001) or Part 11 (commencing with Section 23001).

(b)

The treatment of an item reflected on the return is or may be related to the resolution of an issue in the proceeding or investigation.

(c)

The return or return information relates or may relate to a transactional relationship between a person who is a party to the proceeding and the taxpayer, which affects or may affect, the resolution of an issue in the proceeding or investigation.
In addition, the Attorney General may inspect any report or return required under this part when required in the enforcement of any public or charitable trust or in compelling adherence to any charitable purposes for which any nonprofit corporation is formed.

Source: Section 19547, https://leginfo.­legislature.­ca.­gov/faces/codes_displaySection.­xhtml?lawCode=RTC§ionNum=19547.­ (accessed Apr. 24, 2025).

Last Updated

Apr. 24, 2025

§ 19547’s source at ca​.gov