Tax Type
Corporation Income Tax
Description
Protective claim pending correction of assessment
Topic
Taxpayers' Remedies
Date Issued
01-04-1989
January 4, 1989
Re: §58.1-1821 Application; Corporation Income Tax Request for Conference
Dear*****************
This is in response to your letter of November 16, 1988, in which you requested a conference to further discuss the issues involved in your application for correction of an erroneous assessment and my determination letter of October 17, 1988. After discussing the matter with a member of my staff you indicated that you would withdraw your request and file a protective claim on the net operating loss deduction issue pending in Dominion Bankshares Corporation v. Department of Taxation.
Your recent return for F.Y.E. 2/28/88 claiming an overpayment has not yet been processed. When it is, the overpayment will be credited to the outstanding assessment and the balance will be billed to you. once the assessment has been paid you may file a protective claim for refund limited to the net operating loss deduction issue.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner