On October 5, 2012, the Department assessed the Taxpayer for unpaid gross receipts tax, penalty and interest for the tax period from January 31, 2006, through November 30, 2012. The Taxpayer filed a protest to the assessment in regard to the penalty, but admitted liability to the principal and interest. At the hearing, a representative of the Taxpayer, who was not employed by the Taxpayer in 2006, testified that the Taxpayer’s controller at the time, a CPA, performed “due diligence” in determining whether the Taxpayer’s activities were subject to tax in each state they did business in. The Taxpayer was unable to provide evidence as to what type of review was done by the CPA, or that the Taxpayer relied on incorrect tax advice of the CPA. The Taxpayer was unable to prove that it was not negligent in failing to file gross receipts tax for the period in question. The Taxpayers’ protest was denied.
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