C.C.A. 201310029 (Jan. 14, 2013)

(question raised as to whether CA residents can deduct the CA Fire Prevention Fee as a real property tax; fee enacted via 2011 legislation requiring State Board of Equalization to charge up to $150 as fire prevention fee on each structure in "state responsibility area"; under Treas. Reg. Sec. 1.164-4(a), to be deductible, real property tax must be levied for general public welfare at like rate against all real property in taxing authority's jurisdiction, and assessed amount on specific property benefitted by local benefit (such as for streets, etc.) not deductible as real property tax; fee at issue not deductible as real property tax because it is not a tax under either federal or CA law, is not levied at a like rate, is not imposed against all real property throughout taxing authority's jurisdiction, and is assessed only against specific property to provide local benefit).