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relevann to the taxpayer's contention. The assessor may hold a <br />conference with the taxpayer if requested by the taxpayer, or <br />require submission of additional information and documents, <br />further audit, or other evidence deemed necessary for a proper <br />and equitable determination of the applications. The <br />assessment shall be deemed prima facie correct. The assessor <br />shall undertake a full review of the taxpayer's claims and <br />issue a determination to the taxpayer setting forth its <br />position. Every assessment pursuant to an audit shall be <br />accompanied by a written explanation of the taxpayer's right to <br />seek correcnion and the specific procedure to be followed in <br />the jurisdiction (e.g., the name and address to which an <br />application should be directed). <br /> <br /> (b) Provided an application is made within 90 days of an <br />assessment, collection activity shall be suspended until a <br />final determination is issued by the assessor, unless the <br />assessor determines that collection would be jeopardized by <br />delay or that the taxpayer has not responded to a request for <br />relevant information after a reasonable time. Interest shall <br />accrue in accordance with the provisions of section 20-3(f), <br />but no further penalty shall be imposed while collection action <br />is suspended. The term "jeopardized by delay" includes a <br />finding that the application is frivolous, or that a taxpayer <br />desires (i) to depart quickly from the locality, (ii) to remove <br />his property therefrom, (iii) to conceal himself or his <br />property therein, or (iv) to do any other act tending to <br />prejudice, or to render wholly or partially ineffectual, <br />proceedings to collect the tax for the period in question. <br /> <br /> (c) Any person assessed with a license tax under this <br />ordinance as a result of an audit may apply within ninety days <br />of the determination by the assessing official on an <br />application pursuant to subsection (e) (1) above to the Tax <br />Commissioner for a correction of such assessment. The Tax <br />Commissioner shall issue a determination to the taxpayer within <br />ninety days of receipt of the taxpayer's application, unless <br />the taxpayer and the assessing official are notified that a <br />longer period will be required. The application shall be <br />treated as an application pursuant to Section 58.1-1821 of the <br />Code of Virginia, and the Tax Commissioner may issue an order <br />correcting such assessment pursuant to Section 58.1-1822 of the <br />Code of Virginia. Following such an order, either the taxpayer <br />or the assessing official may apply to the appropriate circuit <br />court pursuant to Section 58.1-3984 of the Code of Virginia. <br />However, the burden shall be on the party making the <br />application to show that the ruling of the Tax Commissioner is <br />erroneous. Neither the Tax Commissioner nor the Department of <br />Taxation shall be made a party to an application to correct an <br /> <br />9 <br /> <br /> <br />