Tax News

CCH (cch.taxgroup.com) reports:

  In a case of first impression, the Vermont Supreme Court applied the economic substance doctrine to disregard the existence of a taxpayer's holding companies and upheld the bank franchise assessment and substantial underpayment penalty that was imposed against the taxpayer. In addition, the Court affirmed the lower court's finding that the Department's actions to collect the erroneous refund were undertaken within the statute of limitations period and that the Tax Commissioner had the authority to independently impose the substantial underpayment penalty against the taxpayer during the taxpayer's administrative appeal.