On May 5, 2021, the Department assessed the Taxpayer for 2019 personal income tax, penalty, and interest. On June 19, 2021, the Taxpayer filed a formal protest of the assessment. The protest at issue is based on the credit for taxes paid that was claimed and denied by the Department for California nonbusiness rental income. The Hearing Officer determined based on the statute and the evidence provided, the Taxpayer failed to demonstrate that they were entitled to the credit. The Hearing Officer determined that the protest is to be denied.