The California Office of Tax Appeals (OTA) had jurisdiction to consider a taxpayer’s appeal of the Franchise Tax Board’s (FTB) denial of a claim for refund of an unclaimed property credit for the 2018 tax year. Neverthless, the appeal was moot. The FTB argued that the OTA had no jurisdiction over the matter, because it had already applied the credit to the taxpayer’s 2019 tax year, so no overpayment remained on the taxpayer’s 2018 tax year account to refund. But, at the time the FTB denied the taxpayer’s claim, there was a credit recorded on the taxpayer’s 2018 tax year account. Thus, the claim for refund was perfected, and the FTB’s denial of a refund of the credit provided the taxpayer with the right to appeal to the OTA. Because the taxpayer timely appealed, the OTA had jurisdiction to hear the appeal. The FTB’s subsequent transfer of the unclaimed property credit to the taxpayer’s 2019 tax year account did not retroactively negate the fact that the taxpayer timely appealed the FTB’s denial of a perfected refund claim. However, the appeal was dismissed as moot because the taxpayer received the entire unclaimed property credit plus interest as a refund after the FTB processed the taxpayer’s 2019 tax year income tax return. Jones, California Office of Tax Appeals, 2026-OTA-288P, April 6, 2026