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This topic is from last year's tax filing.
I see there is "should file" and not "must file."
https://www.ftb.ca.gov/forms/Search/home/results/5050
The FTB has also confirmed that no penalties will be imposed for taxpayers who fail to file Form 4197, Information on Tax Expenditure Items, with their tax return. Taxpayers who received PPP loan forgiveness, Economic Injury Disaster Loan (EIDL) advance grants, or who operate cannabis businesses are asked to complete this form to assist the FTB in fulfilling its state-mandated data collection requirements regarding recently enacted tax benefits. However, because this form is not an “information return” there is no consequence for failing to file the return.
From: https://www.caltax.com/search-results/338775/2/10/
https://www.caltax.com/search-results/338196/3/12/
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