it is my understanding that the Buck Act and the Agreement on Coordination of Tax Administration (ACTA) create a federal zone such that the FTB is essentially an arm of the IRS. Hence all state liability is based on having a federal liability...

I tired tonight and just going through some threads and ran across this one, but I will post some info on the ACTA and how it is how the states clone title 26 and act as agents of the National Government.

peace - scott