Consequences of Failing to Report Federal Changes to the California FTB or Filing State Returns

On Oct. 14, 2021, the Ninth Circuit Court of Appeals in Berkovich affirmed the decision from the Bankruptcy Appellate Panel (BAP) that because a debtor failed to report Internal Revenue Service (IRS) tax assessments to the California Franchise Tax Board (FTB), the debtor’s state tax liability was nondischargeable under § 523(a)(1)(B)(i).