The California Department of Tax and Fee Administration held its second interested parties meeting concerning the Department’s proposed revisions to its sales and use tax Audit Manual Chapter 13 (Statistical Sampling) and Chapter 4 (General Audit Procedures). The Department relies on statistical sampling during audits of large taxpayers to determine and project audit errors. The meeting and comments focused primarily on three proposed revisions by the Department: (1) elimination of the three-error rule; (2) treatment of progress payments; and (3) nonrecurring errors.








attempt to situs NASCAR Holdings, Inc.’s broadcast revenue, media revenue, licensing fees, and sponsorship fees to Ohio. The court’s opinion in NASCAR Holdings, Inc. v. McClain, Slip Op. No. 2022-Ohio-4131 (Nov. 22, 2022), confirms that under Ohio law receipts based on the right to use intellectual property may be sitused to Ohio only if the receipts, i.e., the underlying payments, are tied to a specific right to use the property in Ohio.
(COP) method to determine the fair value of Sirius XM’s services performed in Texas. 