We provide here a written summary of answers provided by the Department of Revenue to the committee at periodic question and answer sessions. These documents are classified as Revenue information issued for informational purposes only for the convenience of PICPA members. Pursuant to 61 Pa. Code Section 3.4, these documents should not be relied upon for any purpose or used in tax appeals. Taxpayers requiring a binding opinion on a specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.
Q&A with the Pennsylvania Department of Revenue
How is the state handling the automatic notices that were sent out to taxpayers that left apportionment Schedule A-1 lines 4A and 4B blank, entering the ultimate percentage on line 5?
How is the state handling the automatic notices that were sent out to taxpayers that left apportionment Schedule A-1 lines 4A and 4B blank, entering the ultimate percentage on line 5? The state has interpreted this as 100% apportionment (i.e. zero over zero) and assessed tax. We have appealed such notices to the Board of Appeals and received information requests for additional support, such as apportionment data, federal returns and balance sheets. Is the state aware of this cumbersome approach and can it do anything to expedite or simplify this procedure to correct what amounts to an administrative mistake?
The Board of Appeals sends information requests letters to Petitioners when additional information is deemed necessary to resolve an appeal. Each information request letter from the Board of Appeals is created to specifically pertain to the facts and circumstances presented in each individual appeal.