Q&A with the Pennsylvania Department of Revenue

How should a taxpayer handle a notice of assessment for a year in which the appeal deadline has passed regarding the former Capital Stock/Foreign Franchise Tax (CSFT)?

Jan 12, 2018
Q:

How should a taxpayer handle a notice of assessment for a year in which the appeal deadline has passed regarding the former Capital Stock/Foreign Franchise Tax (CSFT), but the increase in tax is due to a change in prior year book income that is under appeal? The additional tax should not be due unless the taxpayer is unsuccessful in its appeal for the prior year. Would a lien be filed for the current year?

A:

If the appeal deadline has passed for the current year and the prior appeal has not been resolved, their recourse would be to pay the increase in tax and petition for refund. There would be no additional lien imposed except for the increase in tax, unless the prior appeal is not determined before the current year goes through all the collection steps. If the appeal is decided in the taxpayers favor and the statute of limitations has not expired on the current year, a redetermination could be done.

Leave a comment

Watch: 2019 Q&A with the DOR
Watch: 2019 Q&A with the DOR

Watch Now

A PICPA member login is required to access this content. A full transcript is also available.

Full Transcripts:
Annual Meetings
     
Oct. 2019      Oct. 2018

Oct. 2017      Oct. 2016

  Sept. 2015     Sept. 2014

Full Transcripts:
Quarterly Meetings
Disclaimer

These documents provide a summary of the answers provided by the Department of Revenue to the PICPA Committee on State Taxation at its annual question and answer session. 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 their specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.