AB259-ASA1,2,45
73.16
(3) (b)
This subsection
Paragraph (a) does not apply to any period
6associated with an audit determination, if the period begins after the promulgation
7of a rule, dissemination of written guidance to the public or to the person who is
8subject to the audit determination, the effective date of a statute, or the date on which
9a tax appeals commission or court decision becomes final and conclusive and if the
10rule, guidance, statute, or decision imposes the liability as a result of the tax issue
11described in par. (a) 1.
This subsection does not apply to any period associated with
1an audit determination if the taxpayer did not give the department employee
2adequate and accurate information regarding the tax issue in the prior audit
3determination or if the tax issue was settled in the prior audit determination by a
4written agreement between the department and the taxpayer.
AB259-ASA1,2,76
73.16
(3) (c) Paragraph (a) does not apply to any period associated with an audit
7determination if any of the following applies:
AB259-ASA1,2,108
1. The department establishes by substantial evidence that the taxpayer
9provided incomplete or false information relevant to the tax issue in the prior audit
10determination.
AB259-ASA1,2,1311
2. The tax issue was settled in the prior audit determination by a written
12agreement between the department and the taxpayer that was entered into before
13the effective date of this subdivision .... [LRB inserts date].
AB259-ASA1,2,1814
3. The tax issue was settled in the prior audit determination by a written
15agreement between the department and the taxpayer that was entered into on or
16after the effective date of this subdivision .... [LRB inserts date], and in which the
17parties acknowledge that the department did not adopt the taxpayer's position on the
18tax issue.
AB259-ASA1,2,2220
(1)
Reliance on past audits. This act first applies to an audit determination
21issued on the effective date of this subsection, regardless of when a prior audit
22determination was issued.