Taxpayer received a notice of proposed deficiency from the Franchise Tax Board stating that Taxpayer could not take the Qualified Small Business Stock Gain exclusion after selling his corporation. Taxpayer went through audit, a protest, a settlement hearing trying to fight the proposed assessment. Abajian Law requested a hearing with the Board of Equalization and drafted briefs in preparation for the hearing. Weeks before the hearing, Abajian Law was cc’d a memorandum written to the BOE stating, “after further review of the arguments raised by appellants in their supplemental briefing, the Franchise Tax Board is now prepared to withdraw the $93,007 proposed deficiency assessment for the taxable year.” The appeal was dismissed before the hearing.