Tax Type
Corporation Income Tax
Description
Audit adjustments; Apportionment factors
Topic
Allocation and Apportionment
Date Issued
11-17-1994
November 17, 1994
Re: §58.1-1821 Application: Corporate income taxes
Dear******
This will reply to your letter of October 28, 1994, in which you request an adjustment of the assessment of additional corporate income taxes to***********(the "Taxpayer") for the taxable years ended December 31, 1989 and 1990.
The Taxpayer received a ruling from the Tax Commissioner dated October 28, 1994, copy attached, in which certain corporate tax assessments were adjusted. Upon review of the adjustments, the Taxpayer discovered that three adjustments to the apportionment factors were still required. These adjustments were factual in nature, and had previously been given to the auditor. The Taxpayer did not mention these items it its original protest because it assumed that these adjustments had already been made by the auditor.
The adjustments which the Taxpayer desires at this time are factual in nature. Accordingly, the assessments shall be adjusted. The assessment for 1989 and the refund for 1990 shall be adjusted as provided herein and as reflected on the attached schedules. The net balance due, ******should be paid within 30 days to prevent the accrual of additional interest. Your payment may be sent to Office of Tax Policy, Department of Taxation, P.O. Box 1880, Richmond, Virginia 23282-1880.
Sincerely,
Danny M. Payne
Tax Commissioner
OTP/8600M
Rulings of the Tax Commissioner