Wednesday, August 1, 2012

Revenue Finds its Proposed Assessment and its Denial of Taxpayer's Refund not "Time Barred"

Taxpayer manufactures and markets various pharmaceutical products and services. Taxpayer is involved in research and development, production, and marketing of the pharmaceuticals. Taxpayer filed amended Indiana adjusted gross income tax returns claiming refunds for the 2004, 2005, and 2006 tax years. The Department of Revenue (The Department) issued refund checks for the 2005 and 2006 tax years on April 1, 2009.

Subsequently, the Department conducted a corporate income tax audit for the 2004, 2005, 2006, and 2007 tax years. For the 2004 tax year, the audit resulted in the partial refund of the tax requested. For the 2005, 2006, and 2007 tax years, the audit resulted in the assessment of additional adjusted gross income tax.


Taxpayer claims that the proposed assessments issued for the 2005 and 2006 are barred by the statute of limitations. Taxpayer relies on IC § 6-8.1-5-2(g) which states:  If any part of a listed tax has been erroneously refunded by the department, the erroneous refund may be recovered through the assessment procedures established in this chapter. An assessment issued for an erroneous refund must be issued:  (1) within two (2) years after making the refund; or
(2) within five (5) years after making the refund if the refund was induced by fraud or misrepresentation.


The Department is unable to agree that the 2005 and 2006 assessment is barred by IC § 6-8.1-5-2(g) because there is no indication that the 2005 and 2006 refunds were "erroneous." There is no indication that Taxpayer filed false returns leading to the 2005 or the 2006 refunds; there is no indication that the 2005 or 2006 refunds were generated due to faulty or incorrect information contained in Taxpayer's returns; there is no indication that the 2005 and 2006 refunds were attributable to a calculation error on the part of the Department; there is no indication that the refunds were attributable to an error contained in the Department's records or its computer system. The refunds issued on April 1, 2011, were applied for and issued in the ordinary course of the Taxpayer's business and the ordinary course of the Department's business. At the time the refunds were issued, there was nothing "erroneous" about the refunds because both Taxpayer and the Department believed that the refunds were based upon a correct application of the facts and the law.


Taxpayer claims that the Department's partial denial of its refund is barred by the statute of limitations. Taxpayer states:

The Department did not review the 2004 amended return until the audit began in April 2009. At the completion of the audit at the time the assessments were issued for the 2005, 2006, and 2007 tax years, i.e., [August, 23, 2011] the auditor denied the refund claim for 2004. This denial was outside the statute of limitations, and thus, the Department has no choice but to issue the refund claim for the 2004 year since a waiver to extend the 2004 statute was not executed by the Taxpayer.

It appears that Taxpayer argues that the Department is required to issue a refund within the three year statute of limitations for issuing assessments provided in IC § 6-8.1-5-1 and the three year time period a taxpayer has to file its refund claim.


Accordingly, the statute is silent on how long the Department has to issue a refund, but does provide a three-year limit for a taxpayer to claim its refund within three years of the later of the date of the tax payment or the due date of the tax return. The statute contains a second limitation that a taxpayer must appeal to Tax Court within three years of requesting its refund claim. The statute gives a taxpayer the right to appeal to Tax Court if the Department has not made a decision on the refund claim within one hundred and eight days of receiving the claim. Thus, when the Department has not responded after one hundred and eighty days, but before three years have expired, a taxpayer can consider its refund claim "deemed denied" and appeal to Tax Court. This is the remedy that the statute provides. The statute does not automatically deem a refund granted. In fact, under Taxpayer's logic, all a taxpayer would have to do is file its refund request on the last date it is allowed, the Department would not be able to investigate the claim, and the Department would be required to issue the refund. The Department does not agree with Taxpayer's logic and acted appropriately issuing the partial denial of Taxpayer's refund in its audit report dated July 22, 2011.