1. South Dakota v. Wayfair (2018) 138 S.Ct. 2080
Introduction Betty and Kristen
Betty to ask warm up questions

2. South Dakota v. Wayfair (2018) 138 S.Ct. 2080
S106: Requires certain sellers to collect tax if $100,000 in sales or 200 or more in-state deliveries
Emergency legislation goes into effect pending constitutionality
Sued three vendors: Wayfair, Newegg, Overstock — each with over $1 billion in sales into South Dakota.
No retroactive application – majority opinion liked this feature – avoids Due Process concerns.
Betty

3. South Dakota v. Wayfair Majority
Majority overturned 51 years of precedent
Bellas Hess
Physical presence required for both Due Process and Commerce Clause purposes.
Stressed compliance burden on small businesses
Quill - clarified and went a step beyond
Growth in catalog sales push case to SCOTUS
Physical presence is the wrong standard
Contrary to modern Commerce Clause application
Arbitrary, formalistic, unfair—not best measure of presence.
“[W]hile nexus rules are clearly necessary,” the Court “should focus on rules that are appropriate to the twenty-first century, not the nineteenth.” Hellerstein, Deconstructing the Debate Over State Taxation of Electronic Commerce, 13 Harv. J.L. & Tech. 549, 553 (2000). Each year, the physical presence rule becomes further removed from economic reality and results in significant revenue losses to the States. (at 2092.)
Betty

4. South Dakota v. Wayfair Concurrence
J.Thomas: Takes opportunity to reaffirm his disavowal of Dormant Commerce Clause:
“Our dormant commerce cases usually prevent States from discriminating between in-state and out-of-state firms. Bellas Hess and Quill, do just the opposite. For years they have enforced a judicially created tax break for out-of-state Internet and mail-order firms at the expense of in-state brick-and-mortar rivals. As Justice White recognized 26 years ago, judges have no authority to construct a discriminatory ‘tax shelter’ like this. The Court is right to correct the mistake and I am pleased to join its opinion.” (at 2100.)
Betty

5. South Dakota v. Wayfair Dissent
Roberts, Breyer, Sotomayor, Kagan
Focused on stare decisis and letting Congress intervene
Majority’s rebuttal:
“Although we approach the reconsideration of our decisions with the utmost caution, stare decisis is not an inexorable command.” (at 2096.)
“It is inconsistent with the Court's proper role to ask Congress to address a false constitutional premise of this Court's own creation. Courts have acted as the front line of review in this limited sphere; and hence *2097 it is important that their principles be accurate and logical, whether or not Congress can or will act in response. It is currently the Court, and not Congress, that is limiting the lawful prerogatives of the States.” (at )
Betty

6. South Dakota v. Wayfair California’s Implementation
CDTFA
Long-arm statute applies, that is already the law.
Application to drop-shipments
Jurisdiction goes as far as Constitution permits
Believes full extent of Constitution is $100,000 or 200 transactions.
FTB income tax nexus standard - $500,000 in sales.
CDTFA wants to move forward with regulations. Questions:
Appropriate thresholds
Impact on in-state sellers
Most efficient out-of-state collection process
When will obligation begin
How long will businesses have to come into compliance
Impact on local/district taxes
Cost of implementation
Risk of litigation
Betty

7. South Dakota v. Wayfair: California’s Implementation (cont’d)
CDTFA (cont’d)
Scheduled stakeholder meeting Wednesday 10/24/18
Not imposing retroactive liability - only prospective 
They are going to issue notice some time before the end of the year regarding compliance with RTC 6203
First part of 2019 is when notice will require compliance.
Indicated that they won’t wait for legislation to issue regulations
Legislature
Will have its own stakeholder process, regardless of what CDTFA does
Legislature wants to understand implications directly from taxpayers.
Concerned about confusion for taxpayers and “awkward dynamic” if it imposes nexus standard “different from” CDTFA
Concerned about compliance obligations for small businesses.
Betty

8. The California Office of Tax Appeals: Beyond the Basics Kristen Kane, Chief Counsel, California Office of Tax Appeals
Introduction Betty and Kristen
Betty to ask warm up questions

9. Taxpayer Transparency and Fairness Act of 2017
Authorizing legislation: Assembly Bill 102, signed into law June 27, 2017
Limited elected BOE’s authority to constitutionally mandated tax oversight
Transferred responsibility for most taxes & fees previously administered by elected BOE to newly created California Department of Tax and Fee Administration (CDTFA)
Created new Office of Tax Appeals (OTA)
Trailer bill: Assembly Bill 131, signed into law September 15, 2017
Trailer bill to clarify aspects of the Taxpayer Transparency and Fairness Act of 2017, with immediate effect as of September 20,
Kristen

10. Functional Changes: Transfer of authority from elected Board of Equalization (BOE) to New California Department of Tax & Fee Administration (CDTFA), and California Office of Tax Appeals (OTA)
Kristen- Historical background to BOE

11. Functional Changes to the Role of the Elected BOE Members
Reduction in responsibility and staffing
No administrative appeals to elected board if tax or fee is not administered by the elected Board
No ex parte communications regarding matters before the elected board
See amended California Government Code section 15600
Reduced to constitutional functions only
Betty

12. California Department of Tax & Fee Administration (CDTFA)
Staffed by former BOE professionals
Organizational placement within the GOA
Retains authority to resolve matters without involving appeal to the Office of Tax Appeals
Director appointed by Governor, subject to Senate confirmation –Nick Maduros
Website bears striking resemblance to former BOE website
Betty

13. What Will OTA Hear?
Franchise Tax Board (FTB)
Income and Bank and Corporation Tax examinations and Notices of Action “NOA”
Claims for Refund denials
Assessment and collection actions
California Department of Tax and Fee Administration (CDTFA)
Sales and Use Taxes
Cigarette & Tobacco Products Tax
Motor Vehicle Fuel Tax
Covered Electronic Waste Recycling Fee
Diesel Fuel Tax
Energy Resources (Electrical) Surcharge
Fire Prevention Fee
Hazardous Waste Disposal Fee (Non-substantive Appeal)
Jet Fuel Tax
Lead-Acid Battery Fees
Lumber Products Assessment
Marine Invasive Species (Ballast Water) Fee
Oil Spill Prevention, Response, and Administration Fees
Prepaid Mobile Telephony Services (MTS) Surcharge
More
Kristen 13

14. Office of Tax Appeals The Taxpayer’s Experience
Expressly not a Tax Court, per AB 131
Three-member panels of ALJs- How are they selected?
Hearings not limited by rule in time- established per case
Anyone age 18 or older may be authorized to represent a taxpayer before a tax appeals panel
Generally, all adjudicative hearings and proceedings conducted according to the Administrative Procedure Act, and OTA regulations
Office of Tax Appeals The Taxpayer’s Experience
Kristen w/Betty to add in her experience

15. Independent, Neutral Decision-Making
ALJs appointed, not elected
Statutory requirements:
Active membership in the California State Bar for at least the preceding five years
Knowledge and experience with regard to tax and fee laws of California and the United States
ALJ, not advocates except for the law and for fairness
Regulations forming a code of conduct are in emergency form and were adopted January 1, 2018; the law includes permission to adopt and use emergency regulations until January 1, 2019
OTA Executive Director “shall not direct, oversee, supervise or be otherwise involved in the decision making process of the tax appeals panels”
No ex parte communications by the parties with the tax appeals panels
Independent, Neutral Decision-Making
Kristen –
Bett- to go over ALJ training

16. Office of Tax Appeals The Taxpayer’s Experience
Kristen
Office of Tax Appeals The Taxpayer’s Experience

17. Office of Tax Appeals Right to Judicial Appeal of OTA Decision
Petition for Rehearing at OTA
If a taxpayer disagrees with the decision of the tax appeals panel, the taxpayer may bring a refund action in California Superior Court in accordance with the law imposing the tax or fee for a trial de novo
Administrative remedies must be exhausted; e.g., claim for refund, denial or deemed denial of claim
Office of Tax Appeals Right to Judicial Appeal of OTA Decision

18. Publication of Authority
Precedential authority of elected BOE published decisions
Few formerly precedential decisions are still precedential unless overturned by an OTA ruling
Sales and Use Tax Annotations are as reliable as in the past
Taxpayers may actin reliance on the prior published authority
New OTA panel decisions are precedential if marked precedential (there is one now)
All decisions will be posted on the OTA website both precedential and non.
Kristen

19. Contact us!
Kristen E. Kane, Chief Counsel California Office of Tax Appeals, Sacramento, CA

20. The Implications of Dynamex: California’s adoption of the ABC test for Purposes of Wage Orders.
Introduction Betty and Kristen
Betty to ask warm up questions

21. BACKGROUND
In 1989, the Supreme Court in S.G. Borello & Sons, Inc. v. Dept. of Industrial Relations issued a plethora of factors to consider when determining whether a worker was an “employee” or an “independent contractor” in a workers’ compensation case.
Up until 2018, the Borello test was the standard used in CA to determine the classification of a worker for most purposes.
In 2018, the Supreme Court in Dynamex Operations West, Inc. v. Superior Court of Los Angeles abandoned the Borello test and mandated that an ABC test be utilized for determining whether a worker was an “employee” or an “independent contractor” with regard to wage orders.
The Court adopted Massachusetts’ version of the ABC test
Betty

22. BORELLO FACTS
Borello concerned whether farmworkers hired by a grower to harvest cucumbers under a written “sharefarmer” agreement were independent contractors or employees for purposes of the California workers’ compensation statutes.
The grower contended that the farmworkers were independent contractors.
Using the following test, the court concluded the workers were employees entitled to workers’ compensation as a matter of law:
Betty

23. The Borello test involves the principal factor of ‘whether the person to whom services is rendered has the right to control the manner and means of accomplishing the result desired’ as well as the following nine additional factors:
(1) right to discharge at will, without cause;
(2) whether the one performing the services is engaged in a distinct occupation or business;
(3) the kind of occupation, with reference to whether in the locality the work is usually done under the direction of the principal or by a specialist without supervision;
(4) the skill required in the particular occupation;
(5) whether the principal or the worker supplies the instrumentalities, tools, and the place of work for the person doing the work;
(6) the length of time for which the services are to be performed;
(7) method of payment, whether by the time or by the job;
(8) whether or not the work is part of the regular business of the principal; and
(9) whether or not the parties believe they are creating the relationship of employer-employee
BORELLO FACTORS
Kristen w/Betty to add in her experience

24. BORELLO Application
Borello explained that “the individual factors cannot be applied mechanically as separate tests; they are intertwined and their weight depends often on particular combinations.”
Betty

25. The Massachusetts ABC Test
The Dynamex case abandoned the Borello test and instead adopted the Massachusetts’ version of the ABC Test.
The Massachusetts ABC Test states: An employer who wants to treat someone as an independent contractor rather than an employee has to show that the work:
is done without the direction and control of the employer; and
is performed outside the usual course of the employer's business; and
is done by someone who has their own, independent business or trade doing that kind of work.
Betty

26. DYNAMEX FACTS
Charles Lee and Pedro Chevez were hired by Dynamex as delivery drivers to transport packages, letters and parcels to Dynamex customers. Prior to 2004, Dynamex classified its California drivers as employees, but in 2004, the company converted all drivers from employees to independent contractors. In 2005, several drivers filed suit alleging they performed the same tasks as contractors as they performed when they were classified as employees; as a consequence, they said, the reclassification violated California law. The plaintiffs sought to represent approximately 1,800 drivers engaged as independent contractors.
Betty

27. The standard begins with a presumption that all service providers to businesses are employees unless the business proves otherwise.
The worker is an independent contractor if:
(A) the worker is free from the control and direction of the hirer in connection with the performance of the work;
(B) the worker performs work that is outside the usual course of the hiring entity’s business; and
(C) the worker is customarily engaged in an independently established trade, occupation, or business of the same nature as the work performed for the hiring entity.
THE DYNAMEX ABC TEST
Kristen w/Betty to add in her experience

28. DYNAMEX PRONG A
The “A” prong test is similar to the control factor in Borello.
The worker must be “free of the control of the hiring entity in the performance of the work.”
A myriad of factors may evidence control of the employer over the worker’s performance of work.
Whether the worker supplies his own tools or controls the specific details of his work, without interference by the hiring entity, etc.
The Court confirmed that a business “need not control the precise manner or details of the work” in order to be found to have maintained the necessary control sufficient to lead to a finding of employee status.
Betty

29. DYNAMEX PRONG A
If a business could not pass the Borello test, it would likely not pass this prong of the ABC test.
To some extent, this prong should be the threshold for determining status regardless of whether the ABC test or Borello test applies
Betty

30. DYNAMEX PRONG B
The worker must “perform work that is outside the usual course of the hiring entity’s business.”
The court never defines “usual course of business” in the opinion but to illustrate the meaning of the “usual course of business,” the Supreme Court gave the following examples:
“When a retail store hires an outside plumber to repair a leak in a bathroom on its premises or hires an outside electrician to install a new electrical line, the services of the plumber or electrician are not part of the store’s usual course of business and the store would not reasonably be seen as having “suffered or permitted” (the California law definition of employment) the plumber or electrician to be working as its employee…
Betty

31. DYNAMEX PRONG B
…. “On the other hand,” the Court said, “when a clothing manufacturing company hires work-at-home seamstresses to make dresses from cloth and patterns supplied by the company that will thereafter be sold by the company,” or “when a bakery hires cake decorators to work on a regular basis on its custom-designed cakes,” the workers are part of the hiring entity’s usual business operation and the hiring business can reasonably be viewed as having suffered or permitted the workers to provide services as employees” and not as independent contractors.
Betty

32. The B Test is Unclear and hard to Satisfy
How a business is defined is not always clear and from who’s perspective should it be looked at? From the employee, the employer or the government?
What if it is a national store and has its own maintenance crew? Suppose they hire a retired plumber or electrician that is a friend of the manager of the store and offers to fix it for a small fee?
Suppose the seamstress does work for 10 other companies and market themselves as such?
The Court in Dynamex failed to fully analyze these situations.
Betty

33. Curry v. Equilon Enterprises, LLC, 2018 Cal Lexis 3162.
This case was published a few weeks after Dynamex. The case involved whether an employee of a company that leased services stations from Shell was also an employee of Shell. The Court applied the analysis of the ABC test and held:
B factor requires an examination of whether the worker performs works that is outside the usual course of the hiring entity’s business. The court concluded that Shell held real estate and sold gas and therefor the management of two gas stations fell outside the Shell’s business. Shell was not in the business of operating fuel stations.
Published opinion suggests that it is possible to draw a distinction between two businesses, and thus could support arguments for a referral agency.
Betty

34. DYNAMEX PRONG C
The worker “must be customarily engaged in an independently established trade, occupation or business of the same nature as the work performed,”
Requires a showing that the worker has “independently made the decision to go into business for himself or herself.”
Such workers would be expected to have taken “the usual steps to establish and promote his or her independent business,” for example through “incorporation, licensure, advertisements, routine offerings to provide the services of the independent business to the public or to a number of potential customers, and the like.”
Betty

35. DYNAMEX PRONG C
The “C” prong is potentially problematic for many businesses. While arguably the C prong was part of the Borello test, the new test appears to require that the individual (1) was already in business for himself and (2) works in a customary independent profession.
What this test does is allows the worker or trier of fact to argue than not enough was done to establish a business.
Betty

36. DYNAMEX APPLICATION
If the ABC test determines the worker to be an independent contractor then a California wage order adopted by California’s Industrial Welfare Commission (“IWC”) would not apply.
The service provider has no voice in this process. The business must establish all three prongs.
Betty

37. BORELLO VS DYNAMEX
Did the Supreme Court in Dynamex intend to replace the Borello factors with the new ABC test?
The Supreme Court was quick to point out that their analysis in the Dynamex case applied specifically to California statutes involving wage orders.
However, the Court left open whether this test would also apply to other statutes
Betty

38. Recommended Practices
1. Analyze whether the worker would be exempt. Dynamex only applies to wage order and thus is only affects non-exempt employees.
2. Analyze whether it matter if they are subject to wage orders. Wage order generally impact the following issues: wage, meal and rest periods, overtime, reporting time pay, payment for required uniforms and rules relating to meals and lodging. Suppose you hire an IC for 3 four hour shifts a week. Assume you pay minimum wage. No impact.
3. Wage orders address limited issues. Borello still applies to everything other than a wage order, but beware that the ABC test may go beyond that.
4. Recognize that there are unanswered question about the application of the ABC test. Does it apply prospectively or retroactively? Apparently the Court has agreed to decide this issue.
Betty

39. Recommended Practices
5. Transportation businesses may have a unique exemption under the FAAAA. In Massachusetts Delivers Association v. Coakley, the First Circuit held that the FAAAA preempts the “B” prong of the Mass. ABC test.
6. Carefully review the business. Define the business.
7. Ensure that the business can meet the “A” and “C” prong tests.
Betty

40. Betty

41. Amendments to Section 13052.5 of the CUIC
Assembly Bill (AB) 1695, Allows for the Administrative Appellate Review Under Sections 1221 and 1222 of the CUIC
Betty

42. Biographies: Mardiros H. Dakessian
Mardiros “Marty” Dakessian founded Dakessian Law to build the premier law practice dedicated to representing California taxpayers. This strong sense of purpose, combined with Marty's deep and abiding commitment to his clients, drives him to relentlessly defend their interests with loyalty, integrity and distinction. And the results he has achieved for his clients speak for themselves. Marty not only has a track record of success both at the administrative level and in court, he has shown an unprecedented ability to hold taxing agencies accountable. Four times in the last four years have the agencies paid Dakessian’s clients’ attorneys’ fees totaling over $2.7 million.
Immediately before starting Dakessian Law, Marty ended a successful run as equity partner at Global 20 law firm Reed Smith LLP where he led his team to numerous, impactful administrative and judicial victories. For his efforts, Marty was named “Tax MVP” in 2013 and 2014 by legal publication Law360, which lauded him as “a
top-flight litigator.” He received two more Law360 Tax MVP awards in each of Dakessian Law’s first two years—earning him a total of four Law360 Tax MVPs—more than any other California state and local tax lawyer. Marty's efforts have even attracted the attention of the California Legislature, with legislative staff referring to him as a "noted tax attorney."
Marty has more than 20 years of California tax experience, beginning his career with the State Board of Equalization—California’s administrative tax court and the world’s second largest taxing agency. Marty worked for two of the five members who ran the Board—first as graduate research assistant to the Honorable Dean F. Andal, and then as legal counsel to the Honorable Claude W. Parrish, who was Chair of the Board in 2000 and thus served on the three-member Franchise Tax Board, and who is the current Orange County Tax Assessor. During Marty’s time at the State Board of Equalization, he was responsible for advising Mr. Parrish regarding California franchise and income tax, sales tax and property tax issues. These issues involved taxpayer cases before the Board as well as regulatory, litigation and policy matters.
Observing the inner workings of California’s tax agencies combined with years of experience representing taxpayers has made Marty particularly adept at navigating California’s complex and unique tax system. Law
360 agrees, stating that Marty’s experiences have given him “an easy familiarity with the public and private spheres of state tax practice and have been a boon to clients searching for the best ways to fight state
assessments.” Although these qualities distinguish him from others in the field, so does his passion for representing taxpayers. As Law 360 observed, “his victories are strongly linked to the love he has for his work.

43. Robert Horwitz 
Robert Horwitz is a principal with Hochman, Salkin, Rettig, Toscher & Perez, PC, in Beverly Hills, CA, where he specializes in the representation of clients in civil and criminal tax cases. He has served as a member of the Executive Committee of the Taxation Section of the State Bar of California and as Chair of the Taxation Section for Before entering private practice, Mr. Horwitz was a trial attorney in the U.S. Department of Justice Tax Division and the U.S. Attorney’s Office in Los Angeles.
Mr. Horwitz has been a speaker on tax matters at the Annual Meeting of the Taxation Section of the California Bar, the ABA Section of Taxation Mid-Year Meeting, the UCLA Tax Controversy Institute, and the California State Bar Annual Meeting. He has authored articles on tax law that have appeared in diverse publications, including Tax Notes, the CCH Journal of Tax Practice & Procedure, the Federal Lawyer (the publication of the Federal Bar Association), the California Tax Lawyer and the California Journal of Tax Litigation.
Mr. Horwitz is a member of the bars of California and Illinois. He is admitted to practice before the U.S. Supreme Court, the U.S. Courts of Appeal for the Seventh, Ninth and Federal Circuits, the U.S. District Courts for the Central, Southern, Northern and Eastern Districts of California, the U.S. Court of Federal Claims and the U.S. Tax Court. He was named a Southern California Super Lawyer 2010, 2011, 2012, 2014, 2015, 2016, 2017 and He is a member of the American College of Tax Counsel and of the Planning Committee of the UCLA Tax Controversy Institute.

44. Kristen Kane David Martinez
Kristen Kane, of Sacramento, was appointed chief counsel for the Office of Tax Appeals, by Governor Brown on October 2, Prior to this appointment, she served as deputy director of the California Competes Tax Credit Program at the Governor's Office of Business and Economic Development (GO-Biz) since. Kane served as tax counsel at the California Franchise Tax Board from 2010 to 2016, where she was a graduate legal assistant in She was an attorney at the Legal Aid Society of San Diego from 2009 to Kane earned a Master of Laws degree in taxation and a Juris Doctor degree from the University Of San Diego School Of Law.
David Martinez
David Martinez is an Area Audit Manager with the Employment Development Department (EDD) and is responsible for EDD’s Audit Program in the Central and West Los Angeles County Region. David oversees the audit program in an area that is home to businesses of all sizes and all industries including professional business services, entertainment, manufacturing, construction, transportation, food service, and retail.
David holds a BS degree from California State University Northridge and has worked for EDD’s Audit program for the last 25 years.

45. David Lee Rice, APLC
Professional Experience. Mr. Rice has been in private practice since November 1979 as a tax professional. Prior to law school, Mr. Rice worked for the accounting firm of Coopers & Lybrand. Mr. Rice is the sole proprietor of the law firm of David Lee Rice, APLC, rated AV by Martindale & Hubbell for the last 15 years, and is one of Los Angeles Magazine’s Super Lawyers for Mr. Rice is a member of the American College of Tax Counsel. Mr. Rice was a tenured Professor in accounting at Cal Poly Pomona where he was in charge of all the tax classes. Mr. Rice has taught on the Masters of Taxation Program at California State University at Northridge and Golden Gate University, as well as many courses at the University of West Los Angeles School of Law.
Specialization. Mr. Rice is a Certified Specialist in Taxation with the State Bar of California and is also a Certified Specialist in Elder Law.
Notable Cases: Mr. Rice, in Hlavacek vs. U.S., overturned Treasury Regulation Section (g). In 2017, Mr. Rice won an innocent spouse case which resulted in the IRS conceding a $40,000,000 tax liability.
Publications & Lectures. Mr. Rice has published numerous articles which have been published in the Tax Developments Journal, Journal of Tax Practice and Procedure, Journal of Taxation, the Estate Planning Journal, Practicing Law Institute, University of Southern California Tax Institute, UCLA Tax Institute, California Tax Lawyer, Los Angeles Lawyer, Association of Certified Family Law Specialists, the Daily Journal and Tax Notes. Additionally, Mr. Rice has drafted numerous papers for presentations to the IRS and Treasury concerning substantive changes to the Tax Code and the Treasury Regulations thereunder and has testified before the IRS, Department of Treasury, House Ways and Means Committee and Senate Finance Committee. Mr. Rice has also lectured before the Internal Revenue Service, USC Tax Institute, Annual UCLA Tax Institute, American Bar Association, Annual Meeting of the California Tax Bar and California Tax Policy Conference, HELP, South Bay Bar Association, Beverly Hills Bar Association, Loyola Law School, California Society of CPAs, Orange County Society of CPAs, Estate Planning Counsels of Los Angeles, South Bay and San Fernando, Dean Whittier, Jewish Federation Council, Anti- Defamation League, Kaiser Permanente, Miller & Company, California State Bar Educational Institute, Annual California State Bar Meetings, the Los Angeles County Bar Association, COSMA, and before various Elder Care Groups sponsored with the Los Angeles County Bar Association in conjunction with the Los Angeles County Board of Supervisors.
Associations. Former Chair to the Individual and Family Income Tax Section of the American Bar Association, Former Chair of the State Bar Income Tax Committee, Former Chair of the Los Angeles County Bar Association Committee on Procedure and Litigation, Former Chair of the State Bar Committee on Procedure and Litigation, Former Commissioner and Chair of the Board of Legal Specialization Committee of the State Bar on Taxation, Former Chair of the Tax Section of the Beverly Hills Bar Association, Former Vice Chair of the Executive Committee of the Los Angeles County Bar Association’s Tax Section, Planning Committee for the UCLA Tax Institute, Planning Committee for California State University Polytechnic Pomona Tax Institute, National Academy of Elder Law Attorneys, California Advocates for Nursing Home Reform, Beverly Hills Bar Association, Los Angeles County Bar Association, South Bay Bar Association, South Bay Estate Planning Council, Former Director on the Board of Directors of the Wellness Center.