Tax Type
Corporation Income Tax
Description
Consolidated returns checked as combined
Topic
Returns/Payments/Records
Date Issued
12-08-1986
December 8, 1986
Re: §58.1-1821 Application: Corporation Income Tax
Dear **************
This will reply to your letter of September 22, 1986 in which you seek relief of assessments of corporation income tax and interest against Taxpayers for 1982 and 1983.
Facts
Taxpayers underwent a field audit for 1982 and 1983 and their consolidated return was disallowed and changed to a combined return. Taxpayers have been filing consolidated Virginia returns but have been checking the "combined return" box.
Determination
Taxpayers improperly denoted as "combined" their 1982 and 1983 Virginia corporation income tax returns. However, in that Taxpayers have been filing consolidated Virginia returns, I see no grounds for requiring Taxpayers to file on a combined basis. Accordingly, the audit will be adjusted to permit the consolidated filing for 1982 and 1983.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner