The California State Board of Equalization has issued an informational letter in response to questions proposed at the recently held amnesty information meetings. The letter specifically addresses what the Board thought were the main areas of concern. Those areas are: the 10-year statute of limitations, impact of the 10-year statute of limitations on audits, amnesty for petitioned notices of determination, and credits as applied to amnesty eligible tax liabilities. In regards to how the 10-year statute of limitations (SOL) works, the Board offered the explanation that the SOL allows the Board to issue a notice of determination within ten years of the original due date of the tax liability being assessed, but only if the notice of determination is issued on or after April 1, 2005 for amnesty eligible tax reporting periods in which the taxpayer underreported or did not reports its tax liability. The ten-year SOL only applies to eligible tax reporting periods for which a notice of determination could still be issued as of August 16, 2004 and keeps these periods open for ten years from the original due date for each tax reporting period. The Board further stated they do not plan to modify their existing three-year audit selection cycle, which is used internally to identify accounts eligible for audit. However, the Board listed certain transactions that would cause them to audit a period outside of the normal cycle. In regards to amnesty for petitioned notices of determination, the Board stated that if a notice of determination is being petitioned, a taxpayer may apply for amnesty for any amounts contained in that notice which relate to amnesty eligible tax reporting periods. Also, the Board stated that it would handle issues regarding credits for refundable overpayments and offsets of overpayments against deficiencies as they are currently handled. (Amnesty IP Meeting Follow-Up Letter, California State Board of Equalization, January 21, 2005)