Are you doing business in multiple states? 50 states equates to 50 distinct and different tax laws, judicial systems and regulatory agencies. To this equation, add self-regulated local governments with their own set of laws and administrative policies and you have daunting compliance responsibilities for any multistate taxpayer.
Conscientious companies interested in proactively managing their state/local taxes often seek tax advice from the pertinent taxing authority. This process can be accomplished either verbally and/or by written submission. Hopefully, when a tax opinion is proffered by the regulatory agency, all is well. But what happens when that advice turns out to be incorrect, resulting in harm to the taxpayer? Is there any recourse?
Perhaps…using the concept of detrimental reliance.