March 4, 2026
Re: § 58.1-1824 Protective Claim: Cigarette Tax
Dear ***** :
This is in response to your letter submitted on behalf of ***** (the “Taxpayer”) in which you request a refund of the Virginia cigarette and tobacco products tax paid for the periods of June 2020 through June 2024.
FACTS
During the periods at issue, the Taxpayer purchased Virginia cigarette tax stamps based on a rate of 3¢ per cigarette. It also paid the tobacco products tax for cigars, pipe tobacco, and snuff at imposed rates. It subsequently filed a protective claim for refund and amended orders for Virginia cigarette tax stamps and amended tobacco products tax seeking a refund on the basis that the rates for the cigarette tax and the tobacco products tax were unconstitutionally increased in the 2020 Appropriation Act (Chapter 1289 of the 2020 Acts of Assembly) and the 2022 Appropriation Act (Chapter 2 of the 2022 Acts of Assembly, Special Session I). The Taxpayer also contends that the Department exceeded its authority by creating a floor tax in the Virginia Cigarette Tax Rate Increase Guidelines and Rules (the “Guidelines”), published as Public Document (P.D.) 20-59 (4/8/2020).
ANALYSIS
Protective Claim
Virginia Code § 58.1-1824 permits taxpayers to file a protective claim for refund within three years of the date of an assessment. Pursuant to the authority granted the Department under Virginia Code § 58.1-1824, a protective claim for refund can be held pending the outcome of another case before the courts or the claim may be decided based upon its merits pursuant to Virginia Code § 58.1-1821. As permitted by statute, the Taxpayer’s request has been treated as an application for correction under Virginia Code § 58.1-1821.
Cigarette Tax
Pursuant to Virginia Code § 58.1-1001 A, any entity selling, storing, or receiving cigarettes for distribution in Virginia must pay an excise tax. Licensed stamping agents are subject to the tax. Authorized dealers purchase Virginia Revenue Stamps, commonly referred to as cigarette stamps, from the Department by completing Form TT-2, Order for Virginia Cigarette Tax Stamps. Cigarette stamps are affixed to each pack of cigarettes to show that the tax has been paid.
Prior to July 1, 2020, the tax was 1.5¢ per cigarette (30¢ per pack of 20 cigarettes). Effective for taxable sales or purchases beginning on and after July 1, 2020, Item 3-5.21 A of the 2020 Appropriation Act increased the cigarette tax from 1.5¢ per cigarette to 3¢ per cigarette (60¢ per pack of 20 cigarettes). This language was retained in Item 3-5.21 A of the 2022 Appropriation Act, which became effective July 1, 2022.
Tobacco Products Tax
Virginia Code § 58.1 1021.02 imposes a tobacco products tax on distributors of cigars, pipe tobacco, smokeless tobacco, loose-leaf tobacco, and moist snuff. Prior to July 1, 2020, cigars, pipe tobacco, smokeless tobacco, and loose-leaf tobacco were taxed at 10% of the manufacturer’s sales price, while moist snuff was taxed at $0.18 per ounce.
Effective for taxable sales or purchases occurring on and after July 1, 2020, Item 3-5.21 B of the 2020 Appropriation Act doubled the tobacco products tax to 20% of the manufacturer’s sales price for cigars, pipe tobacco, smokeless tobacco, and loose-leaf tobacco, and to $0.36 per ounce for moist snuff. In addition, Item 3-5.21 C of the 2020 Appropriation Act imposed a tax on liquid nicotine at the rate of $0.066 per milliliter. Item 3-5.21 D of the 2020 Special Session I Amendments to the 2020 Appropriation Act (Chapter 56 of the 2020 Acts of Assembly, Special Session I) authorized a tax on heated tobacco products equal to the rate of 2.25¢ per stick effective January 1, 2021. Item 3-5.21 of the 2022 Appropriation Act retained the increase to the tobacco products tax, the imposition of a tax on liquid nicotine at the rate of $0.066 per milliliter, and the authorization for a tax on heated tobacco products equal to the rate of 2.25¢ per stick.
Constitutionality of Cigarette and Tobacco Products Tax Increases
The Taxpayer contends that the increases in the cigarette tax and tobacco products tax as set forth in the 2020 and 2022 Appropriation Acts violates both Article IV, §§ 11 and 12 of the Constitution of Virginia and that tax laws cannot be amended through an appropriation act.
The Virginia Supreme Court has stated that “all actions of the General Assembly are presumed to be constitutional.” Virginia Soc’y for Human Life v. Caldwell, 256 Va. 151, 157 (citing Hess v. Snyder Hunt Corp., 240 Va. 49, 52 (1990)). Thus, “a statute will be construed in such a manner as to avoid a constitutional question wherever this is possible.” Virginia Soc’y for Human Life, 256 Va. at 157 (citing Eaton v. Davis, 176 Va. 330, 339 (1940); see also Jacobs v. Meade, 227 Va. 284, 287 (1984)). The Court further stated, “In this context, we will narrowly construe a statute where such a construction is reasonable and avoids a constitutional infirmity.” Id. (citing Pedersen v. City of Richmond, 219 Va. 1061, 1065 (1979)). Deferring to the Virginia Supreme Court’s authority regarding constitutional issues, the Department will, likewise, give the Constitution of Virginia a liberal construction.
Enactment of Laws
Va. Const. art. IV, § 11.states in pertinent part:
Every law imposing, continuing, or reviving a tax shall specifically state such tax. However, any law by which taxes are imposed may define or specify the subject and provisions of such tax by reference to any provision of the laws of the United States as those laws may be or become effective at any time or from time to time, and may prescribe exceptions or modifications to any such provision.
The Taxpayer argues that Va. Const. art. IV, § 11 prohibits the legislature from enacting a tax law through incorporation by reference, “except to any provision of the laws of the United States ...“ Based on this rationale, the Taxpayer asserts that the aforementioned cigarette and tobacco product tax increases violate Va. Const. art. IV, § 11 because the 2020 and 2022 Appropriation Acts referenced the applicable code sections without reenacting Virginia Code §§ 58.1-1001 and 58.1-1021.01. The Taxpayer asserts that the General Assembly is prohibited from amending Virginia’s tax statutes by reference unless the reference is to the laws of the United States. The Department disagrees with this reasoning.
The Virginia Constitution was amended in 1971 to incorporate the language in the paragraph in Va. Const. art. IV, § 11 referenced above. This language expressly permitted the General Assembly to incorporate by reference in a Virginia law the tax laws of the federal government. For example, this provision allowed the General Assembly to adopt rolling conformity to the Internal Revenue Code during its 1971 session (1971 Acts of Assembly, Extended Session, Chapter 171), shortly after Virginia’s voters approved a referendum to revise the Virginia Constitution on November 3, 1970. Both the Constitutional amendment and the adoption of rolling conformity became effective on July 1, 1971. See Implementation of a Simplified Tax System for Virginia Taxpayers: Report of the Income Tax Conformity Statute Study Commission to the Governor and the General Assembly of Virginia (published as 1971 House Document 5).
Contrary to the Taxpayer’s argument, Va. Const. art. IV, § 11 states that “any law by which taxes are imposed may define or specify the subject and provisions of such tax by reference to any provision of the laws of the United States” [emphasis added]. While Virginia’s courts have construed the term “may” to be mandatory when it is necessary to accomplish the manifest purpose of the legislature, the word is prima facie permissive. See Caputo v. Holt, 217 Va. 302 (1976) (citing Chesapeake & O. Ry. Co. v. Pulliam, 185 Va. 908 (1947)) and Harper v. Virginia Dep’t of Taxation, 250 Va. 184 (1995). Unless constrained by a court, Va. Const. art. IV, § 11 permits the referencing of laws of the United States in Virginia’s statutes to clarify and enhance the understanding and administration of the Code of Virginia.
Va. Const. art. IV, § 11 requires that laws amending a tax must include the name of the tax. Item 3-5.21 of the 2020 and 2022 Appropriation Acts is specifically titled “CIGARETTE TAX, TOBACCO PRODUCTS TAX AND TAX ON LIQUID NICOTINE.” In addition, such section in both Appropriation Acts refers to “the cigarette tax imposed under subsection A of § 58.1-1001 of the Code of Virginia” and “the tobacco products tax imposed under § 58.1-1021.02 of the Code of Virginia.” Such references clarify the specific tax being named, as required by Va. Const. art. IV, § 11. As such, the cigarette and tobacco products taxes subject to the increased rates as set forth in the 2020 and 2022 Appropriation Acts were explicitly named in the legislation passed by the General Assembly.
Form of Laws
Va. Const. art. IV, § 12 (the Single-Object Rule) provides that “No law shall embrace more than one object, which shall be expressed in its title. Nor shall any law be revived or amended with reference to its title, but the act revived or the section amended shall be reenacted and published at length.” The Taxpayer argues that both the 2020 Appropriation Act and the 2022 Appropriation Act fail to meet this requirement because they do not include the subject of taxation or, in the alternative, each Act embraces more than one object. In addition, the taxpayer argues that the relevant tax increases violate the second clause because the 2020 and 2022 Appropriation Acts do not state and reenact Virginia Code § 58.1-1001 or Virginia Code § 58.1-1021.
According to the Virginia Supreme Court, the purpose of this section is to prevent members of the General Assembly and the general public from being misled by the title and to prohibit the combining of subjects which are adverse or dissimilar and have no kindred connection into one act. See Board of Supr’s of Henrico County v. McGruder, 84 Va. 828 (1888); Saville v. Richmond, 162 Va. 612 (1934); and Commonwealth v. Dodson, 176 Va. 281 (1940).
The Virginia Supreme Court has opined that this section “was not intended to block honest legislation, and it is to be liberally construed.” Fairfax County Indus. Dev. Auth. v. Coyner, 207 Va. 351, 355 (1966). According to the Court, all that is required “is that the subjects embraced in a statute but not specified in the title be germane to or in furtherance of the objects expressed in the title, or have a legitimate and natural association therewith.” See id.
The title of the 2020 Appropriation Act is as follows:
An Act for all appropriations of the Budget submitted by the Governor of Virginia in accordance with the provisions of § 2.2-1509, Code of Virginia, and to provide a portion of revenues for the two years ending respectively on the thirtieth day of June, 2021 and thirtieth day of June 2022.
The title of the 2022 Appropriation Act is as follows:
An Act for all appropriations of the Budget submitted by the Governor of Virginia in accordance with the provisions of § 2.2-1509, Code of Virginia, and to provide a portion of the revenues for the two years ending respectively on the thirtieth day of June, 2023, and the thirtieth day of June, 2024, and an Act to amend and reenact §§ 3.2-5145.5, 4.1-1100, 4.1-1101, 18.2-325, 18.2-334.6, 22.1-349.1, 58.1-322.02, 58.1-322.03, 58.1-339.8, 58.1-439.30, 58.1-611.1, and 59.1-200 of the Code of Virginia.
Although the Taxpayer admits that the titles above mention appropriations and appropriated funds, the Taxpayer also insists that such titles do not mention taxes or tax increases. The Taxpayer asserts that an appropriation is the setting of a sum for a specific reason and, therefore, is not related to taxation. Alternatively, the Taxpayer argues that, if appropriations are related to taxation, the amendment embraces more than one subject in violation of the Constitution of Virginia.
In Commonwealth v. Dodson, the Virginia Supreme Court interpreted the relevant constitutional language in relation to the subject of an appropriation act. In that case, the Court held that the Governor’s veto of a change to state administrative office and responsibilities in the 1940 Appropriation Act did not violate the Constitution because “[t]hese unsustained vetoes strike out matters which are germane or congruous to an appropriation bill, its provisions and conditions. There is nothing about them which should have misled the Legislature or the people, and certainly there is nothing about them surreptitious.” Dodson, 176 Va. at 310. Clearly, the Court views an appropriation act as one that may include a broad range of provisions. Similarly, the Attorney General has more recently opined that an appropriation act that appropriates money and raises funds by taxes or fees, even without a separate accompanying bill, would not violate Va. Const. art. IV, § 12 because the raising of taxes and fees and appropriating funds in an appropriate act is congruous or germane to the subject matter of the appropriation act. See 2010 Op. Va. Att’y Gen. 15, 47.
The Virginia Court of Appeals recently addressed the same argument raised by the taxpayer in the context of a provision related to the regulation of gambling that was included in an appropriation act. In its analysis, the court stated that “the Supreme Court has long held that ‘the act should not include legislation so incongruous that it could not, by any fair indictment, be considered germane to one general subject.’” Sadler Bros. Oil Co. v. Commonwealth, No. 0463-24-2, slip op. at 6 (Va. Ct App Aug. 12, 2025) (citing Ingles v. Straus, 91 Va. 209, 216 (1895)). The court further quoted the Virginia Supreme Court, stating:
[t]he connection or relationship of several matters, such as will render them germane to one subject and to each other, can be of various kinds, as for example, of means to ends, of different subdivisions of the same subject, or that all are designed for the same purpose, or that both are designated by the same term. Neither is it necessary that the connection or relationship should be logical; it is enough that the matters are connected with and related to a single subject in popular signification.
Id. (quoting Ingles at 216-17). The court in Sadler Bros. Oil Co. held that including provisions related to the regulation of gambling as part of a broader appropriations and budget bill did not violate the single-object rule, stating, “While Ingles makes clear that the connection between the primary subject of an act and a challenged provision does not need to be logical if they are in fact, germane to the object expressed in the title, the relationship between amending the definition of illegal gambling to include skill games and a budget act is inherently logical.” Id. The Court further noted that the gambling provisions at issue in that case directly impacted the Commonwealth’s revenue sources. Id.
Similar to the Sadler Bros. Oil Co. case, the increases in the cigarette and other tobacco products taxes are germane to the object expressed in the titles of the 2020 and 2022 Appropriation Acts. Although not required by the Virginia Supreme Court’s decision in Ingles, the relationship between tax rates and a budget act is inherently logical, as increases in tax rates have a direct impact on the Commonwealth’s revenue sources.
The Taxpayer, citing Beale v. Pankey, 107 Va. 215 (1907), further contends that the statutory language must be stated and reenacted within an appropriation act to be constitutional. Under this rationale, the Taxpayer argues that the cigarette and tobacco tax increases set forth in the 2020 and 2022 Appropriation Acts were not valid because they did not amend and reenact Virginia Code § 58.1-1001 and § 58.1-1021.02, and, as a result, failed to give notice to the public regarding the purported change in law. In Pankey, the General Assembly adopted legislation amending the town charter for Pamplin City, Virginia and appointing certain individuals to serve as mayor and councilmen until an election was held. The Court determined that this legislative change to the charter violated § 52, Article 4 of the Virginia Constitution of 1902 because the body of the enacted legislation “makes no reference whatever to the act which is referred to in the title.” Regardless, the imposition of Pamplin City’s tax was upheld because the earlier act and its charter were still in force. The Department does not find the Taxpayer’s arguments persuasive. Unlike the facts in Pankey, the 2020 and 2022 Appropriation Acts explicitly referenced the relevant Code sections within the body of the legislation. See District Road Board v. Spilman, 117 Va. 201 (1915) (similarly distinguishing Pankey as not on point when considering the application of the revival clause of Va. Const. art. IV, § 12).
The Taxpayer further cites Gilmore v. Landsidle, 252 Va. 388 (1996) to assert that, because the Court stated that the constitutional requirement is satisfied if the amended sections of a bill are reenacted, the cigarette and tobacco tax increases were unconstitutional because the Code of Virginia sections were not reenacted. In Landsidle, the attorney general filed a writ of mandamus on behalf of the Governor seeking to declare an appropriations act adopted by the General Assembly in 1996 unconstitutional because it only included amended items. The appropriation act in dispute was a caboose budget bill, meaning that it included changes to the amended appropriation act for the same biennium previously adopted by the General Assembly during the 1995 General Assembly session. The case did not address the reenactment of statutory language, but rather whether appropriation act language that had already been enacted into law needed to be expressly set forth in the caboose budget bill presented to the Governor for his signature. The Court denied the writ on the basis that enrollment of the complete biennial bill was not necessary, as the Governor maintained the authority to veto any amended item.
The Taxpayer’s argument based on Landsidle is similarly unpersuasive. The Court held that “Article IV, Section 12 and Article V, Section 6 of the Constitution of Virginia did not require enrollment of items of the existing appropriation act which had not been amended in the current legislative section.” Landsidle, 252 Va. at 401. The Court elaborated as follows:
In District Road Board v. Spilman, this Court held that publication of only the amended section of a multi-section act satisfied the publication requirement of the predecessor provision of Article IV, Section 12. We stated that publication of the single amended section met ‘both the letter and spirit of the Constitution.’ Id. at 206, 84 S.E. at 104. The fact that Spilman involved an amendment of a single section, rather than of multiple sections, is not a distribution of constitutional significant, because the notice function of Article IV, Section 12 is satisfied when the public is provided notice of every change made to a law.
Id. at 398.
In the present case, the relevant language in the 2020 and 2022 Appropriation Acts was clearly set forth in the bills, and such language was subsequently reenacted in the appropriation acts adopted in 2020, 2022, 2023, and 2024. See the 2020 Special Session I Amendments to the 2020 Appropriation Act (House Bill 5005, Chapter 56, 2020 Acts of Assembly, Special Session I); the 2022 Amendments to the 2021 Appropriation Act (House Bill 29, Chapter 1, 2022 Acts of Assembly, Special Session I); the 2023 Special Session I Amendments to the 2023 Appropriation Act (House Bill 6001, Chapter 1, 2023 Acts of Assembly, Special Session I); and the 2024 Amendments to the 2023 Special Session I Amendments to the 2023 Appropriation Act (HB 6002, Chapter 1, 2024 Acts of Assembly, Special Session I).
In fact, the Virginia Supreme Court in Landsidle articulated that the purposes of the publication requirement of Article IV, Section 12 included “the prevention of careless amendment of a bill and the provision of clear notice to those affected by an enacted bill.” Landsidle, 252 Va. at 396-397. In the instant case, the language included in the 2020 and 2022 Appropriation Acts provided notice of the tax increase by citing the relevant taxes and Code sections imposing such taxes and clearly stating the changes to the statutory tax rates.
Contrary to the Taxpayer’s claims, the Constitution of Virginia does not require that legislation enacted by the General Assembly include an enactment clause setting forth the entirety of the statutory language being superseded by an appropriation act. See Landsidle at 395 (citing Webster v. Commonwealth, 141 Va. 589 (1925)). However, when an act includes an enactment clause, the Court can rely on such clause to determine the content of legislation. See id (citing District Road Board v. Spilman, 117 Va. 201 (1915)). As such, there was no requirement that the statutory language imposing the cigarette and tobacco taxes be set forth, amended, and reenacted in the 2020 or 2022 Appropriation Acts.
Enactment clauses included in the 2020 and 2022 Appropriation Acts that amended and reenacted the Code of Virginia did so by setting out the full text of the relevant statutes. By contrast, the cigarette and tobacco tax increases in the 2020 Appropriation Act were intended to provide revenue for the 2020-2022 biennium and could be superseded by subsequent Appropriation Acts. The cigarette and tobacco tax increases were, therefore, limited to the effective dates of the relevant Appropriation Acts, with the tax rates set to revert back to the statutorily established rates under Virginia Code § 58.1-1001 and § 58.1-1021.02 upon the expiration of the 2020 Appropriation Act. The General Assembly subsequently extended the tax increases by enacting the 2022 Appropriation Act.
In 2024, the General Assembly enacted legislation amending Virginia Code § 58.1-1001 A to codify the cigarette tax increase and to clarify the imposition of the tax on heated tobacco products equal to the rate of 2.25¢ per stick. See 2024 Acts of Assembly, Chapter 611. The General Assembly also adopted legislation codifying the tax rate on liquid nicotine at the rate of $0.066 per milliliter under Virginia Code § 58.1-1021.02 A 4 a 1. See 2024 Acts of Assembly, Chapter 796.
Guidelines Authority
The Taxpayer contends that the Guidelines unlawfully delegated taxing authority to the Department by allowing it to impose a floor stock tax. It argues that, because authority in the 2020 Appropriation Act was limited to transitional procedures, the Department exceeded its authority when it implemented a floor tax under the Guidelines.
Item 3-5.21 E of the 2020 Appropriation Act states that “[t]he Tax Commissioner shall establish guidelines and rules for (i) transitional procedures in regard to the increase in the cigarette tax, (ii) implementation of the increased tobacco tax rates …” The 2020 Appropriation Act clearly states that the increased rates were effective for taxable sales or purchases beginning on and after July 1, 2020. Accordingly, the Department had the authority to impose the rates that generated the underlying tax liability that the Taxpayer is contesting. The Taxpayer is seemingly contesting the mechanism by which the Department is collecting the additional tax due (i.e., the floor tax).
As of July 1, 2020, any stamps held by wholesalers at the lower tax rate were no longer valid because they did not reflect the increased tax rate. In order to effectuate the cigarette tax increase, stamping agents were required to pay a floor tax and file a floor tax return in lieu of the application of transitional stamps. The floor tax was imposed on any cigarettes bearing the old stamp in the wholesaler’s possession on the day that the higher rate took effect. The tax rate of the floor tax was the difference between the old and new rates.
As stated in the Guidelines, the floor tax was imposed in lieu of the application of transitional stamps. Transitional stamps would have been a greater administrative burden for impacted stamping agents who would have been required to purchase new stamps at the rate differential to reapply to already stamped inventory. The establishment of the floor tax was a one-time imposition on cigarette stamps held by stamping agents that had been purchased at the pre-July 1, 2020 rate in order to transition outstanding stamps from the old tax rates to the new rates. The floor tax provided by the Guidelines only facilitated the transition and implementation of the increased tax rates authorized by the General Assembly. As cited above, the Tax Commissioner was clearly granted the authority to establish guidelines for transitional procedures.
The floor tax has previously been used by the Commonwealth to transition cigarette tax increases whenever required by the General Assembly. In its 2004 Special Session I, the General Assembly passed House Bill 5018, which amended several tax statutes. In particular, this bill raised the excise cigarette tax from .125¢ per cigarette sold to 1¢ per cigarette sold from August 1, 2004 through midnight June 30, 2005, and then raised the tax to 1.5¢ per cigarette sold after July 1, 2005. The Department issued Virginia Cigarette Tax Rate Increase Guidelines and Rules for each of these increases, published as P.D. 04-120 (7/30/2004) and P.D. 05-102 (5/13/2005). Each of these guidelines instituted a one-time floor tax in order to transition the cigarette tax increase in the same manner as the Guidelines.
Retroactive Legislation
Finally, the Taxpayer contends that the 2024 legislation codifying the increased cigarette and tobacco tax rates cannot be applied retroactively. As stated above, the cigarette and tobacco tax increases in the 2020 and 2022 Appropriation Acts did not violate the Constitution of Virginia and the Department did not exceed its authority in establishing the floor tax. As such, the Taxpayer’s argument regarding the retroactive effective date of 2024 Chapter 611 is moot.
DETERMINATION
Pursuant to Virginia Code § 58.1-205 any assessment of tax by the Department is deemed prima facie correct. Under Title 23 of the Virginia Administrative Code (VAC) 10-20-165 A, the denial of a refund claim is deemed to be an assessment. This means that the burden of proof is upon the Taxpayer to establish that the assessment is incorrect.
The Court has repeatedly held that acts of the General Assembly “are presumed to be constitutional unless the contrary is clearly shown.” See Coyner at 355. Further, “every reasonable doubt shall be resolved in favor of [an act’s] constitutionality,” and “courts cannot strike down a statute enacted by the General Assembly unless it clearly appears that such statute does contravene some provision of the Constitution.” Id.
Based on this analysis, the Taxpayer has not met its burden in showing that the Legislature violated Article IV, § 11 or § 12 of the Constitution of Virginia by increasing the cigarette tax from 1.5¢ per cigarette to 3¢ per cigarette or doubling the tobacco products tax through both the 2020 Appropriation Act and the 2022 Appropriation Act. In fact, the tax increases permitted both the Governor and the General Assembly to comply with Va. Const. art. X, § 7. Further, the Tax Commissioner, under authority granted by the General Assembly, developed and instituted the Guidelines for the floor tax. Accordingly, the Taxpayer’s request for a refund of the cigarette and tobacco products taxes paid for the June 2020 through June 2024 period cannot be granted.
Finally, the retroactive enactment of Chapter 611 by the General Assembly in its 2024 session was not arbitrary and did not disturb the Taxpayer’s vested rights or due process. Additionally, the action of the General Assembly was rationally related to the legitimate governmental purpose of raising revenue.
The Code of Virginia section and regulation cited are available online at law.lis.virginia.gov. The public documents cited are available at tax.virginia.gov in the Laws, Rules, & Decisions section of the Department’s website. If you have any questions regarding this determination, you may contact ***** in the Office of Tax Policy and Legal Affairs, Tax Adjudication and Resolution Division, at ***** or *****.
Sincerely,
Kristin L. Collins
Tax Commissioner
Commonwealth of Virginia
AR/4812.B