Tax Type
Corporation Income Tax
Description
Permission to file a combined return
Topic
Returns/Payments/Records
Date Issued
02-26-1986
February 26, 1986
Re: Virginia Code Section 58.1-442
Permission to File a Combined Return
Dear ******************
This will reply to your letters of November 8, and December 20, 1985, requesting permission for the above-referenced taxpayers to file a combined Virginia income tax return for the taxable years ended December 31, 1981 and December 31, 1982.
You have indicated that the taxpayers are members of an affiliated group eligible to file a combined return, but have been filing separate Virginia income tax returns. You further indicate that the above-referenced taxpayers represent all of the members of the affiliated group which are subject to Virginia income tax.
Based on the foregoing representations, permission is hereby granted for the above-referenced taxpayers to file a combined return for the taxable year ended December 31, 1982, and thereafter. The return should be filed using the name and identification number of the Parent. The combined return is to be filed in accordance with the requirements set forth in the Virginia Corporation Income Tax Regulations §630-3-442 (copy enclosed).
As you acknowledge in your letter of December 20, 1985, the three-year period for 1981 ended October 15, 1985. I regret that I am without authority to extend the statute. Accordingly, the request to file a combined return for the taxable year ended December 31, 1981 is hereby denied.
With respect to your proposal to file an amended 1983 combined return, it would be inappropriate for me to comment on a return not filed.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner