[rushpat]

The California FTB thread was getting a bit crowded, so I thought I'd branch this thread out.

I was reading on the net (wish I could remember the URL), that there is no legal, valid liability until there is a legal, valid assessment.

According to those who've battled the IRS on this, an assessment certificate, must be signed by the assessment officer to be valid. Also, this signature must be under penalty of perjury to the facts stated therein.

The Notice of Proposed Assessment I received from the FTB was unsigned, as is all of their correspondence. I'm thinking the same rules apply to them. Also, I read somewhere (still can't remember this URL either) that an assessment officer and a collection officer are supposed to be two different people (and someone acting as both can get into a lot of trouble). I guess it would be hard to prove that the same person didn't try to fill both roles when no one is signing anything.

Anyone care to comment?