Tax Type
Corporation Income Tax
Description
Alternative method of allocation
Topic
Allocation and Apportionment
Date Issued
02-14-1984
- February 14, 1984
Re: Virginia Code § 58-151.051
Alternative Method of Allocation
Dear ****
Taxpayer is a specialty contractor who operates in Virginia and several other states. Taxpayer requests permission to adopt a separate accounting method in filing its Virginia corporate income tax returns.
The department's policy in allowing corporations to use an alternative method of allocation and apportionment is set forth in Corporation Income Tax Circular No. 1 (copy enclosed). The taxpayer has not shown that the statutory method of allocation and apportionment produces an unconstitutional or inequitable result.
Accordingly, permission to adopt a separate accounting is denied. Any returns so filed from the taxable year ending June 30, 1979 and thereafter will have to be amended.
Sincerely,
W. H. Forst
State Tax Commissioner
Rulings of the Tax Commissioner