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CA · jury_instructions

CALCRIM No. 2828

Failure to Withhold Tax (Rev. & Tax. Code, §§ 19708, 19709)

activein force · 2019-01-01 – presentcompiled-edition

The defendant is charged [in Count] with intentionally failing to

(withhold/collect, or truthfully account for,) and pay (a/an) (tax/ [or]

amount required to be withheld) to the Franchise Tax Board [in

violation of <insert appropriate code section[s]>].

To prove that the defendant is guilty of this crime, the People must

prove that:

1. Under state tax laws, the defendant was required to (withhold/

collect, or truthfully account for,) and pay (a/an) (tax/ [or]

amount required to be withheld) to the Franchise Tax Board;

2. The defendant did not do so;

AND

3. The defendant voluntarily chose not to do so, with intent to

violate a legal duty known to (him/her).

[The People do not have to prove the exact amount owed. The People

must prove beyond a reasonable doubt that the amount the defendant

failed to (withhold/collect, or truthfully account for,) and pay to the

Franchise Tax Board was substantial.]

New January 2006

Provenance

Source
courts.ca.gov
Retrieved
2026-08-20
Edition
calcrim-2019
Content hash
40203d2d2c3466e8d2ced34d9f100807c99b271916b13c18d84cf0dd41e87b53
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