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Contact Information:
Edward S. Kisscorni, CPA
290 Suncrest Court, SW
Grandville, MI 49418

Office: 616/233-0667
Cell: 616/443-6730
Fax: 616/233-0667

Blog: www.EdKisscorni.com/Blog1
Email: Ed@EdKisscorni.com
 



 



 

 Blog 
Sunday, October 30 2011

Taxpayer Maintained Adequate records required by Law

In Fradco, Inc. v. Department of Treasury, Michigan Tax Tribunal, No. 409506, September 26, 2011, an assessment of Michigan sales tax against a grocery retailer was cancelled because the Department of Treasury's audit methodology resulted in imperfect estimates and was based on an incomplete sample of purchase invoices extrapolated over a four-year period.  Furthermore, the Department of Treasury failed to consider inventory fluctuations and shrinkage that occurs in retail operations.  

The taxpayer met its burden in challenging the assessment, as the taxpayer demonstrated that its source documents were adequate and well maintained to determine the sales tax due.  The taxpayer's outside CPA testified that the taxpayer maintained receipts, purchase invoices, bills of lading, delivery receipts, and other records used to calculate annual and monthly tax returns.

The Department of Treasury has appeal the Tax Tribunal decision to the Court of Appeals.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Saturday, October 29 2011

Recreational Vehicle Purchased in Florida and Registered in Montana Not Subject to Tax

In Free Enterprises LLC v. Department of Treasury, Michigan Tax Tribunal, No. 379030, August 26, 2011, the Michigan use tax was not due on a recreational vehicle (RV) purchased in Florida, registered in Montana, and subsequently stored in Michigan because there is a presumption of exemption for property brought into Michigan by a resident more than 360 days after its purchase.

The RV was purchased by a Montana LLC that was set up to "acquire, by purchase, lease or otherwise, any real and/or personal property and to dispose of it, in any manner."  The sole member of the LLC, who was a Michigan resident at the time of the purchase, stored the RV in Michigan during the summer months of 2008, 2009, and 2010.  However, this is not the type of storage that leads to imposition of the use tax, where property is brought into the state more than 360 days after its purchase.  The RV spent more time stored in Florida and other states than in Michigan. Though the LLC's sole member took advantage of a Florida sales tax exemption and created the Montana LLC in order to minimize the tax liability of the RV purchase, these circumstances do not overcome the presumption that the RV was not stored, used, or consumed in Michigan.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Friday, October 28 2011

President and Sole Officer Could Not Delegate Responsibility for Tax

In Sova v. Department of Treasury, Michigan Tax Tribunal, No. 383261, August 25, 2011, the owner of a structural steel company was held personally liable for Michigan sales and use tax as a corporate officer because the owner, as president and sole officer of the company, had control or supervision of or was otherwise charged with responsibility for making the returns or payment of taxes.  The owner alleged wrongdoing on the part of the company's controller for the audit period at issue.  However, a corporate officer cannot delegate responsibility for tax matters to third parties or non-officers.  The owner's signature on prior years' sales and use tax and single business tax (SBT) returns was prima facie evidence of liability.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Thursday, October 27 2011

Market Value of Property Negatively Influenced by Wetlands

In Twin Rivers Development v. Township of Macomb, Michigan Court of Appeals, No. 298084, October 20, 2011, the Court of Appeals relying on the Tax Tribunal's findings of fact and conclusions of law affirmed the local Michigan ad valorem property tax assessments levied by a township on property that had been zoned residential but appraised as commercial exceeded the market value of the property because a significant portion of the property was wetlands.  

The Tax Tribunal relied on various witnesses' testimony and reports to determine how much of the property was wetlands. Specifically, it relied on the testimony of an ecological and environmental consultant who determined that approximately seven acres of the 12-acre property contained wetlands.  Although this was only an estimate, the Tax Tribunal was not required to disregard this testimony and accept the township assessor's valuations, which did not take any amount of wetlands into account.  Therefore, the Michigan Court of Appeals concluded that the tribunal's determination that the market value of the property was negatively influenced by the wetlands was supported by competent, material, and substantial evidence on the record.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Wednesday, October 26 2011

Court Rules the Tax Base for the Local Hotel Tax Includes the Online Travel Companies Fees

 

The U.S. District Court for the Northern District of Illinois held that a 7% hotel tax imposed by the Village of Rosemont, Illinois, on the full room rental fees charged by online travel companies (OTCs) is a valid use tax, and it does not violate the dormant Commerce Clause of the U.S. Constitution.  [The Village of Rosement v. Priceline.com, Inc., U.S. District Court, N.D. Illinois, No. 09 C 4438, October 14, 2011]

 

We are reporting this Illinois case in the Michigan State and Local Tax Blog because this same issue is being litigated in Michigan.  In Michigan, the ordinance establishing the room tax imposes the tax on the "person" providing the room accommodation.  The tax is not imposed on the customer.

 

The court first found that the OTCs were "owners" for purposes of the local hotel tax ordinance because customers could not access their hotel rooms until paying the room charge to the OTCs, not the hotels.  An "owner" includes a person who receives consideration for the rental of a hotel or motel room.

 

The court then held that the full rental fees paid by the customers to the OTCs, not just the charges paid by the OTCs to the hotels, were taxable.  OTCs charged Rosemont customers a room rental fee that included (1) the amounts that the hotels charged the OTCs, and (2) the OTCs' markup on the hotels' charges.  The ordinance intended to tax the amount paid by customers to occupy a hotel room in Rosemont.  OTCs' customers paid the OTCs' charges for the right to occupy hotel rooms in Rosemont.

 

The court held that the OTCs' facilitation of travel-related services was incidental to the rental of hotel rooms, and that the hotel tax was a use tax.  Illinois law establishes that a tax on hotel room rentals is a use tax, not an impermissible sales (occupation) tax.  Services generally are not subject to sales tax.

 

In response to an argument made by the OTCs, the court found that the hotel tax did not violate the dormant Commerce Clause.  First, the OTCs had nexus with Illinois because (1) the tax was levied for the right to use a hotel room in Illinois, (2) the tax was paid by the person who uses the room, and (3) the OTCs entered into contracts with hotels in Illinois for the right to market, facilitate, and book reservations and they profit from such reservations.  Second, the tax was fairly apportioned because it is imposed on a use that can occur in only one place. Third, the tax does not discriminate against interstate commerce as it is applied at the same rate to every hotel reservation in Rosemont.  Finally, the tax is related to Illinois services because the renting person has the advantage of the state's police and fire protection, for example, while staying in Illinois.  The court addressed several other federal and state claims made by the OTCs, holding in favor of the village.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Tuesday, October 25 2011

Taxpayer Failed to Obtain and Retain Exemption Certificates

 

In Saline Equipment Inc. v. Department of Treasury, Michigan Tax Tribunal, No. 313377, September 22, 2011, an assessment of Michigan sales tax on sales of tractors and other excavation equipment was upheld because the taxpayer admitted that it did not retain the required exemption certificates and was unable to provide documentary or testamentary evidence that the equipment sold was used for agricultural purposes.  

 

The Tax Tribunal entered an order to deem the Department of Treasury's requests to admit admitted, as the taxpayer submitted an unsigned response more than 28 days after service of the request.  Furthermore, the taxpayer failed to request that the admissions be amended or withdrawn.

 

 

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Monday, October 24 2011

Federal Legislation Introduced in Both Houses of the US Congress

A plan to close the Internet sales-tax loophole in Michigan is inviting praises from storefront businesses but raising some concerns among some legislators about possible "unintended consequences." 

In my Thursday October 13, 2011 Blog, I reported on the Click-Through and Affiliate Nexus Bills Introduced In The Michigan Legislature.  The bills introduced in the Michigan House of Representatives would amend the Sales Tax Act and the Use Tax Act.

House Bill 5004 would amend the sales tax act and House Bill 5005 would amend the use tax act. Both bills contain both affiliate and click-through nexus provisions relating to the sales and use tax collection responsibilities of remote sellers. Both bills have been introduced in the Michigan House of Representatives.

The bills would amend the definition of a person engaging in business in the state by including a seller with an "affiliated person" that has a physical location in the state, conducts business in the state, or is subject to the Michigan sales or use tax, and directly or indirectly, does any of the following:

sells a similar line of products as the seller, under the same or similar business name;

uses its employees or facilities in the state to advertise and promote sales by the seller;

maintains an office, distribution facility, or other similar place of business to deliver tangible personal property sold by the seller to customers in Michigan;

uses trademarks or service marks that are similar to those used by the seller;

delivers, installs, assembles, or performs maintenance or repair services for the seller's customers;

allows the seller's customers to pick up or return tangible personal property sold by the seller at a distribution facility or other similar place of business maintained by the affiliated person; or

performs any other activities associated with the seller's ability to establish or maintain a market in Michigan.

The click-through provisions provide that a seller is engaged in business in the state if it enters into an agreement with one or more Michigan residents under which the resident, for a commission or other consideration, directly or indirectly, refers potential customers, whether by a link on an Internet website, in-person oral presentation, or otherwise, to the seller. The cumulative gross receipts from sales by the seller to customers who are referred to the seller by residents with an agreement with the seller must be greater than $10,000 during the immediately preceding 12 months.

The presumption of nexus, from the activities of an affiliated person or the sales from resident referrals, can be rebutted by showing that the affiliated person or the state residents with whom the seller has an agreement did not engage in solicitation or any other activity related to the seller's ability to establish or maintain a market in the state.

The House Tax Policy Committee heard testimony on Wednesday October 12th on the "Michigan Main Street Fairness Act"  which would close the sales-tax loophole by moving online-only retailers under the same sales-tax collection laws as brick-and-mortar businesses. 

Online retail is a $250 billion industry and growing.  The bill are aimed at helping small businesses compete with online retailers, whose products may seem cheaper because they do not have to charge sales tax.  That appears to be a big savings when people are shopping for high-price items like cameras or jewelry. 

"In the end, the consumer is left exposed with an online tax liability," said Jim HALLAN, CEO and President of the Michigan Retailers Association.  "Many consumers do not know it is their responsibility to track and remit the tax for purchases over the Internet.  They could be subject to an audit for failing to do so." 

Representative Jeffrey Farrington or Utica voiced concerns about changing the definition of nexus in general.  "I am a little concerned about the unintended consequences," Farrington said. "Once you move away from the physical definition of nexus . it becomes something esoteric and pretty much however you want to define it." 

Representative Mark Meadows of East Lansing questioned how the bills would impact the federal legislation introduced in the US Congress which is under consideration to unify and simplify tax codes.  Meadows said the committee should consider supporting the federal legislation in a resolution.

The U.S. House Bill Would Mandate Collection by Remote Sellers

Sellers would be required to collect sales and use tax for states in which they lack a physical-presence nexus, under legislation introduced in the U.S. House of Representatives on October 13, 2011. The Marketplace Equity Act of 2011 (H.R. 3179) was introduced by Representatives Steve Womack of Arkansas and Jackie Speier of california, along with other cosponsors.  It has been referred to the House Judiciary Committee. H.R. 3179 mirrors proposals by the Retail Industry Leaders Association.

Unlike the Main Street Fairness Act, which was introduced in Congress on July 29, 2011 by Illinois Senator Richard Durbin of Illinois, the new legislation would not require a state to conform to the Streamlined Sales and Use Tax (SST) Agreement in order to receive collection authority.  Rather, a state would be authorized to require remote sellers to collect tax for sales into that state, so long as state law provides the following minimum simplifications:

         a small-seller exception for remote sellers with gross annual receipts nationwide of $1 million or less, or in the state of $100,000 or less;

         a single tax return for use by remote sellers and a single authority in the state with which the return must be filed;

         an identical tax base and exemptions throughout the state for remote sellers; and

         a rate structure for remote sellers.

The three acceptable rate structures for remote sellers would be the following:

         a single statewide blended rate that includes both the state rate and local rates;

         the maximum state rate, exclusive of tax imposed by or for local jurisdictions; and

         the destination rate, which would be the sum of the state rate and the local rate of the location into which the sale is made.

The rates for the first two structures could not exceed the average rates applicable to non-remote sellers. A state that requires the destination rate would be required to make available software that eases the burden of collecting at multiple rates and provide liability relief for errors in the information provided. A state that imposes a lower rate for sales of food or drugs and medicine could require remote sellers to collect tax at those rates.

Posted by: Ed Kisscorni AT 01:15 pm   |  Permalink   |  0 Comments  |  Email
Friday, October 21 2011

Legislation Would Codify Definition Contained in Revenue Administrative Bulletin 2007-6

The Michigan House of Representatives has passed a bill that would, if enacted, define "actively solicits" for determining nexus under the corporate income tax. The House version of the bill is the same as the version passed earlier by the Senate.

"Actively solicits" would be defined as:

         speech, conduct, or activity that is purposefully directed at or intended to reach persons within Michigan and that explicitly or implicitly invites an order for a purchase or sale; or

         speech, conduct, or activity that is purposefully directed at or intended to reach persons within Michigan that neither explicitly or implicitly invites an order, but is entirely ancillary to requests for an order for a purchase or sale.

The bill would be effective January 1, 2012.

In its present form, the law is written so that the Michigan Department of Treasury can define "actively solicits" through written guidance to be applied prospectively.  The proposed changes would essentially codify a portion of the guidance that the department provided regarding nexus for the Michigan business tax in Revenue Administrative Bulletin 2007-6.

 

Posted by: Ed Kisscorni AT 01:18 pm   |  Permalink   |  0 Comments  |  Email
Thursday, October 20 2011

Grocery Store Audit Was Based on a Two Month Sample

In SMK LLC v. Department of Treasury, Michigan Tax Tribunal, No. 409504, September 26, 2011, an assessment of sales and use tax against a Michigan convenience store was cancelled because the taxpayer's records were adequate and suitable to determine the amount of tax due.  The taxpayer's daily Z tapes and sales sheets were provided to an outside CPA who used these source documents to determine the monthly sales tax.  Furthermore, the taxpayer had adequate internal controls to ensure that tax was properly collected, as the taxpayer utilized in-store cameras, had the outside CPA reconcile bank accounts on a monthly basis, and produced a purchases journal, a sales journal, a general ledger, and a trial balance on a monthly basis.  The Department of Treasury's calculations did not result in reliable estimates, as they were based on a two-month sample of purchase invoices, extrapolated over a four-year period, using an estimated average mark-up. The department's audit methodology did not consider inventory fluctuations or shrinkage occurring in retail businesses.

Posted by: Ed Kisscorni AT 01:16 pm   |  Permalink   |  0 Comments  |  Email
Wednesday, October 19 2011

Property Was Zoned Residential

In Eldenbrady v. City of Albion, Michigan Court of Appeals, No. 297735, October 4, 2011 taxpayers were entitled to a local Michigan principal residence property tax exemption on their 10-acre parcel that was contiguous to the property on which their home was located because the parcel was zoned residential at the time and was unoccupied.  The Michigan Court of Appeals held that the Michigan Tax Tribunal misinterpreted the exemption provision and committed an error of law when it determined that the 10-acre parcel did not qualify for the principal residence exemption because it contained an abandoned, unimproved, and unused school building and, therefore, was not vacant.

In order to qualify for the principal residence exemption under the applicable provision, the property needed only to be "unoccupied," not "vacant." The court concluded that these two terms were not synonymous for purposes of this case. The exemption provision did not require that contiguous property be vacant or completely devoid of any inanimate objects, contents, or structures to qualify for the principal residence exemption. Instead, the statutory language merely required that the contiguous property be "unoccupied," which meant "without human occupants." No part of the taxpayers' 10-acre parcel or abandoned school building was used as a residence or dwelling, and no part of the parcel or school building had tenants or residents.

 

Posted by: Ed Kisscorni AT 01:15 pm   |  Permalink   |  0 Comments  |  Email
Tuesday, October 18 2011

Senate Joint Resolution Would Increase the Sales Tax Rate by 1% to 7%

A joint resolution that proposes to amend Article IX, Section 8 of the Michigan Constitution in order to increase the sales tax rate by 1%, beginning January 1, 2012, has been introduced in the Michigan Senate. The resolution further proposes that the amendment would be submitted to the people at the next general election.

Posted by: Ed Kisscorni AT 01:13 pm   |  Permalink   |  0 Comments  |  Email
Monday, October 17 2011

Administrators of Pension and Retirement Benefits Required to Withhold Income Tax on Taxable Payments

The Michigan Department of Treasury has issued the 2012 pension withholding guide for personal income withholding tax purposes.  Effective January 1, 2012, administrators of pension and retirement benefits are required to withhold income tax on taxable payments.  Qualified pension and retirement benefits include most payments reported on Form 1099-R for federal tax purposes. For example, defined benefit pensions, IRA distributions, and most payments from defined contribution plans are included.  However, on the other hand, payments received before the recipient could retire under plan provisions or benefits from 401(k), 457, or 403(b) plans attributable to employee contributions alone are not considered pension and retirement benefits.

Taxpayers are required to complete Form MI W-4P (Withholding Certificate for Michigan Pension or Annuity Payments) for each pension or annuity.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Friday, October 14 2011

Michigan Tax Tribunal Dismissed a Taxpayer's Property Tax Appeal

In Quality Behavioral Health, Inc. v. City of Detroit, Michigan Court of Appeals, No. 297664, September 27, 2011, the Michigan Tax Tribunal correctly dismissed a taxpayer's local property tax appeal petition because both the taxpayer and the assessor failed to allege facts indicating mutuality of mistake as required to trigger the applicability of the three-years-from-payment limitation period.  If that limitation period did not apply, the usual time periods applied, and the taxpayer's tax appeal was not timely filed under them.  In this case, the taxpayer did not allege that it told the assessor that its property was a group home. Rather, the taxpayer merely alleged that during an inspection by the city, someone on the premises told the city inspector that the property was a group home.

The Michigan Court of Appeals concluded that the three-years-from-payment time period was a limitations period and not jurisdictional. Accordingly, the tribunal had subject matter jurisdiction under the provision that granted exclusive and original jurisdiction to the tribunal regarding final determinations relating to assessment, valuation, rates, special assessments, allocation, or equalization under the property tax laws.  Although the tribunal possessed subject matter jurisdiction, the failure to satisfy the three-years-from-payment time period rendered the appeal untimely.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Thursday, October 13 2011

Bills Introduced in the Michigan House of Representatives Would Amend the Sales Tax Act and the Use Tax Act

House Bill 5004 would amend the sales tax act and House Bill 5005 would amend the use tax act.  Both bills contain both affiliate and click-through nexus provisions relating to the sales and use tax collection responsibilities of remote sellers.  Both bills have been introduced in the Michigan House of Representatives.  

The bills would amend the definition of a person engaging in business in the state by including a seller with an "affiliated person" that has a physical location in the state, conducts business in the state, or is subject to the Michigan sales or use tax, and directly or indirectly, does any of the following:

         sells a similar line of products as the seller, under the same or similar business name;

         uses its employees or facilities in the state to advertise and promote sales by the seller;

         maintains an office, distribution facility, or other similar place of business to deliver tangible personal property sold by the seller to customers in Michigan;

         uses trademarks or service marks that are similar to those used by the seller;

         delivers, installs, assembles, or performs maintenance or repair services for the seller's customers;

         allows the seller's customers to pick up or return tangible personal property sold by the seller at a distribution facility or other similar place of business maintained by the affiliated person; or

         performs any other activities associated with the seller's ability to establish or maintain a market in Michigan.

The click-through provisions provide that a seller is engaged in business in the state if it enters into an agreement with one or more Michigan residents under which the resident, for a commission or other consideration, directly or indirectly, refers potential customers, whether by a link on an Internet website, in-person oral presentation, or otherwise, to the seller. The cumulative gross receipts from sales by the seller to customers who are referred to the seller by residents with an agreement with the seller must be greater than $10,000 during the immediately preceding 12 months.

The presumption of nexus, from the activities of an affiliated person or the sales from resident referrals, can be rebutted by showing that the affiliated person or the state residents with whom the seller has an agreement did not engage in solicitation or any other activity related to the seller's ability to establish or maintain a market in the state.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Wednesday, October 12 2011

Use Tax Exemption Enacted

Beginning April 1, 2012, Michigan use tax will no longer apply to Medicaid contracted health plans and specialty prepaid health plans.  [Public Act 141 (S.B. 347), Laws 2011, effective September 20, 2011]

With the enactment of the Health Insurance Claims Assessment (HICA) Act, beginning January 1, 2012, a 1% assessment will be imposed on a carrier and third-party administrator's paid claims.  The assessment will be 0.1% for a carrier with a suspension or exemption under section 3717 of the Insurance Code of 1956 as of September 20, 2011.  The assessment must not exceed $10,000 per insured individual or covered life annually.  The tax will sunset on January 1, 2014.  [Public Act 142 (S.B. 348), Laws 2011, effective September 20, 2011]

For a group health plan that utilizes the services of a third-party administrator or an excess loss or stop loss insurer, the assessment will be the responsibility of the administrator or insurer, and not the group health plan sponsor.  Every carrier or third-party administrator subject to assessment must file returns on April 30, July 30, October 30, and January 30 of every year for the preceding calendar quarter.  The Department of Treasury may require payment by electric funds transfer.  Records must be kept for four years after the assessment.

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Tuesday, October 11 2011

MACPA Seminar in Grand Rapids to Address the Top Ten Michigan Sales and Use Tax Issues

It seems like the number of sales and use tax audits are on the increase.  Maybe it's the increase in field auditors. Or, maybe it's the number of frustrating issues.  Many Michigan taxpayers are facing difficult audits.  All of these issues will be addressed at a MACPA Sales and Use Tax seminar scheduled for Friday, October 28, 2011 in Grand Rapids.

Ctrl+Click and follow the link for more information and to register on line.

Michigan Sales & Use Tax (MSUTD)

Friday, October 28, 2011

WMU Downtown Conference Center - Grand Rapids, MI - Credits: 8.0 OT

 

This course provides a complete review of the Michigan Sales and Use Tax.  A combination of a review of the law, case studies, examples and discussion is used to identify who is subject to tax, the exemptions, and record keeping requirements.

 

Ed Kisscorni's Top Ten Michigan Sales and Use Tax Issues

 

1.      The ten year audit

2.      Michigan vendor liability

3.      Bundled transactions/single mixed transactions

4.      Affixation to realty

5.      Sale of a service v sale of tangible personal property

6.      Delivery charges

7.      Installation charges

8.      Transfer of title or transfer of ownership

9.      Interstate trucking

10.  Audit techniques

Posted by: Ed Kisscorni AT 01:00 pm   |  Permalink   |  0 Comments  |  Email
Monday, October 10 2011

Due Date for Filing Without Penalty Extended to December 31, 2011, Legislation Pending

The Michigan Department of Treasury has revised a notice stating that while disregarded entities for federal tax purposes are required to file Michigan Business Tax (MBT) returns, the due date to file the returns is extended to December 31, 2011 (previously, October 31, 2011).

This latest notice was originally published on November 29, 2010.  At that time, affected persons were required to file a return, or amend a return for prior period, by June 30, 2011. This due date, in a Notice dated April 30, 2011, was revised to October 31, 2011. This due date, after which penalties will be assessed, is now again revised to December 31, 2011.

 

A person that is a disregarded entity for federal tax purposes, including a single member limited liability company or QSub, must file a separate return under the MBT or file as a member of a unitary business group if the requirements of MCL 208.1117(6) are satisfied.  This requirement applies to all open tax periods under the MBT.  A person disregarded for federal tax purposes that filed as a sole proprietor, branch, or division of its owner for MBT purposes (a "previously disregarded entity") is considered a non-filer for statute of limitations purposes under MCL 205.27a.

 

A person that previously filed an MBT return that included one or more previously disregarded entities, including a unitary business group, must amend its returns for all open periods, even if the amended returns do not result in a different tax liability.

 

A person required to file a return, or amend a return for a prior period, under this Notice must do so by December 31, 2011.

 

Posted by: Ed Kisscorni AT 01:12 pm   |  Permalink   |  0 Comments  |  Email

 

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