in-20250528-IR-045250253NRA: DEPARTMENT OF STATE REVENUE
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Taxpayer argues that the Department erred in denying it a refund of collection costs and fees. Taxpayer is an out-of-state finance private equity firm. Taxpayer routinely files Indiana C- Corporation returns. Taxpayer filed the IT-20 return for the period ending March 31, 2019. As a result, the Department issued Taxpayer a Notice of Proposed Assessment dated July 14, 2020. The notice explained as follows. The July 2020 letter explained that 100 percent of its income (approximately $20,000,0000) should have been sourced to Indiana rather than the zero percent originally reported. Subsequently, the Department issued a “Demand Notice for Payment.” The notice was dated September 23, 2020, and indicated as follows. Taxpayer decided that it should have received the entire $600,000. In January 2024, Taxpayer submitted a “Claim for Refund” in the form of a GA-110L seeking the return of the $73,000. In February 2024, the Department responded stating that it was denying the claim for return of the $73,000 because “DOR did not receive any indication of reasonable cause to support this abatement [refund].” Taxpayer disagreed and submitted a protest to that effect. An administrative hearing was conducted in order to allow Taxpayer’s representatives an opportunity to explain why the Department’s refund denial was wrong. This Final Order Denying Refund results.
The agency’s own summary, as published.
The rule, in full
334 words as published, May 28, 2025. View the original →
DEPARTMENT OF STATE REVENUE FINAL ORDER DENYING REFUND: 02-20241792 Corporate Income Tax For the Tax Period April 1, 2018, to March 31, 2019 HOLDING ISSUE
I. Tax Administration – Collection Costs.
Authority: IC 6-8.1-5-1; IC 6-8.1-8-2; IC 6-8.1-8-4; IC 6-8.1-10-3; P/S, Inc. v. Ind. Dep’t of State Revenue, 853 N.E.2d 1051 (Ind. Tax Ct. 2006). Taxpayer argues that the Department erred in denying it a refund of collection costs and fees. STATEMENT OF FACTS Taxpayer is an out-of-state finance private equity firm. Taxpayer routinely files Indiana C- Corporation returns. Taxpayer filed the IT-20 return for the period ending March 31, 2019. As a result, the Department issued Taxpayer a Notice of Proposed Assessment dated July 14, 2020. The notice explained as follows. The July 2020 letter explained that 100 percent of its income (approximately $20,000,0000) should have been sourced to Indiana rather than the zero percent originally reported. Subsequently, the Department issued a “Demand Notice for Payment.” The notice was dated September 23, 2020, and indicated as follows. The September letter cautioned. Taxpayer decided that it should have received the entire $600,000. In January 2024, Taxpayer submitted a “Claim for Refund” in the form of a GA-110L seeking the return of the $73,000. In February 2024, the Department responded stating that it was denying the claim for return of the $73,000 because “DOR did not receive any indication of reasonable cause to support this abatement [refund].” Taxpayer disagreed and submitted a protest to that effect. An administrative hearing was conducted in order to allow Taxpayer’s representatives an opportunity to explain why the Department’s refund denial was wrong. This Final Order Denying Refund results.
I. Tax Administration – Collection Costs and Fees.
DISCUSSION The issue is whether Taxpayer was responsible for paying costs incurred by the Department’s collection agent. IC 6-8.1-5-1(b) provides in relevant part: When a proposed amount remains “unpaid,” the Department added a penalty as provided for under IC 6-8.1-8-2(b). FINDING Taxpayer’s protest is respectfully denied. March 7, 2025 Replaces Finding Document: New
Documents
- Full text (state register) · May 28, 2025
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