In Matter of Gatewood Corp, OTA Case No. 19105425 (July 3, 2024), the California Office of Tax Appeals (“OTA”) concluded that Gatewood Corporation’s (“Gatewood”) transfer of stock did not entitle it to a $10 million deduction because the transaction lacked economic substance and was for the purpose of tax avoidance, resulting in $831,398 additional tax.  The California Franchise Tax Board (“FTB”) conceded a $332,559 non-economic substance transaction (“NEST”) penalty that it had originally imposed. In…