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

What is the status of the JP Morgan Securities, Inc. and New Cingular Wireless PCS cases, and what is the income producing activity/cost of performance appeals that the Department may litigate?

Nov 15, 2019
Q:

What is the status of the JP Morgan Securities, Inc. (Commonwealth Court Dkt. Nos. 663-666 FR 2016) and New Cingular Wireless PCS, LLC (Commonwealth Court Dkt. Nos. 1001-1002 FR 2013, 16-2 17 FR 2016, 151-153 FR 2018), and what is the income producing activity/cost of performance appeals that the Department may litigate?

A:

JP Morgan Securities, Inc. (Commonwealth Court Dkt. Nos. 663-666 FR 2016)
were closed by stipulations for judgment satisfied August 7, 2019. New Cingular Wireless PCS, LLC (Commonwealth Court Dkt. Nos. 1001-1002 FR 2013, 16-17 FR 2016) are in the discovery phase of litigation. New Cingular Docket Nos. 151-153 FR 2018 are being reviewed by the Court separately due to jurisdiction issues.
 

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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.