Document Number
88-100
Tax Type
Corporation Income Tax
Description
Protective claim for refund; ACRS subtractions
Topic
ACRS Modifications
Subtractions and Exclusions
Date Issued
05-12-1988
May 12, 1988



Re: §58.1-1824 Protective Claim for Refund
§58.1-323 ACRS Additions; F.Y.E. 6/30/84


Dear******************


This is in response to your letter of March 14, 1985, and our letter of July 30, 1985 advising you that your client's case would be held without action pending resolution of another case in which similar issues were involved.

Virginia law requires all taxpayers to make additions and subtractions with regard to ACRS deductions reported on their federal returns. We have recently ruled that these modifications must be made by Real Estate Investment Trusts. See ruling letter dated March 30, 1987, P.D. No. 87-89 (copy enclosed). The same principles apply to a cooperative such as your client. Accordingly, your protective claim for refund is denied.


Sincerely,



W. H. Forst
Tax Commissioner

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