OPINION D. MESSINA AND N. MESSINA

The Office of Tax Appeals

This government document is issued by The Office of Tax Appeals for use in California

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https://www.google.com/url?client=internal-element-cse&cx=001779225245372747843:omqfkwsvk9w&q=https://ota.ca.gov/wp-content/uploads/sites/54/2021/05/19064905_Messina_Opinion_Revised_050321SDwm.pdf&sa=U&ved=2ahUKEwiT7KH4mIXyAhVu-ioKHbfGAuU4KBAWMAl6BAgEEAE&usg=AOvVaw3h-A5-zz3I-QmM-Hfg5cDG

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