In Yamaha Corp. of America v. State Bd. of Equalization (1998) 19 Cal.4th 1, the Supreme Court determined that a tax opinion drafted by a board staff attorney was not an official administrative interpretation and was entitled only to "respectful nondeference." ( Id. at p. 11, fn. 4.) The court reasoned: "Considered alone and apart from the context and circumstances that produce them, agency interpretations are not binding or necessarily even authoritative. To quote the statement of the Law Revision Commission in a recent report, 'The standard for judicial review of agency interpretation of law is the independent judgment of the court, giving deference to the determination of the agency appropriate to the circumstances of the agency action.'" ( Id. at p. 8, italics omitted.) In Yamaha Corp. of America v. State Bd. of Equalization, the Supreme Court distinguished the standard of review of the exercise of an agency's quasi-legislative rulemaking function and agency interpretations of the meaning of a statute. A less deferential standard applies to the latter pronouncements. (Id. at pp. 6, 11.) Even so, ". . . 'the judiciary, although taking ultimate responsibility for the construction of the statute, accords great weight and respect to the administrative construction.' " (Id. at p. 12.) The Yamaha court determined that the weight to be given to an agency's construction of a statute is "situational" and depends on consideration of two categories of relevant factors. (Yamaha Corp. of America v. State Bd. of Equalization, supra, 19 Cal. 4th at p. 12.) The court referred to factors " 'indicating that the agency has a comparative interpretive advantage over the courts,' and those 'indicating that the interpretation in question is probably correct.' Citations." (Ibid.) In Yamaha Corp. of America v. State Bd. of Equalization, the California Supreme Court discussed the degree of deference owed to administrative interpretations of a statute. The degree of deference that is due is "fundamentally situational. A court assessing the value of an interpretation must consider a complex of factors material to the substantive legal issue before it, the particular agency offering the interpretation, and the comparative weight the factors ought in reason to command." (Yamaha Corp. of America, supra, 19 Cal. 4th at p. 12.)