Document Number
93-76
Tax Type
Corporation Income Tax
Description
Apportionment factor adjustments
Topic
Allocation and Apportionment
Date Issued
03-19-1993

March 19, 1993



Re: Va. Code §58.1-1821 Application: Corporation Income Taxes
Taxable Years 1988 and 1989


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

This will reply to your letter dated May 6, 1992 in which you protest certain audit adjustments made for the above-referenced taxable years to the ************************** (the "taxpayer"). All of the contested adjustments are those made with respect to apportionment factor information.

Your proposed adjustment pertaining to the payroll factor is not correct This is because total wages reported on Forms VEC-20 are presumed to be compensation paid or accrued in Virginia for the reporting company, except when there is compensation paid or accrued in Virginia which is not subject to the Virginia Unemployment Act See Virginia Regulation 630-3-412.

I am not able to make a determination regarding your other protest concerns, since there are factual, nonpolicy issues involve. Therefore, the assessment will be returned to the Interstate Audit Unit for reconsideration in light of the details raised in your letter.


Sincerely,




W. H. Forst
Tax Commissioner

OTP/6226G

Rulings of the Tax Commissioner

Last Updated 08/25/2014 16:46