Judges: K. N. AYERS
Agency: Department of Financial Services
Latest Update: Mar. 14, 1979
Summary: Prior year's income is not income for Florida tax purposes even though it is reported as income on the taxpayer's federal return. Recommend refund.
78-1227.PDFSTATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
FLORIDA POWER CORPORATION, )
)
Petitioner, )
)
vs. ) CASE NO. 78-1227
)
GERALD A. LEWIS, et al., )
)
Respondent. )
)
RECOMMENDED ORDER
Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, K. N. Ayers, held a public hearing in the above styled case on 20 October 1978 at Tampa, Florida.
APPEARANCES
For Petitioner: Blair W. Clark, Esquire
Richard W. Neiser, Esquire Post Office Box 14042
St. Petersburg, Florida 33733
For Respondent: E. Wilson Crump, II, Esquire
Assistant Attorney General Department of Legal Affairs The Capitol, Room 1502 Tallahassee, Florida 32304
By Petition filed 5 July 1978 the Florida Power Corporation, Petitioner, seeks refund of $619,697 in corporate income taxes paid in 1973. As grounds therefor it is alleged that the original income tax return was in error and that the amended tax return in which depreciation was recalculated showed the correct amount of corporate income taxes due and the difference between the amount of corporate taxes paid and the amount owed according to the amended return should be refunded. Petitioner's contention that denial of refund violates the Florida Constitution is an issue beyond the jurisdiction of this tribunal.
There is no dispute regarding the facts in this case. One witness was called by Petitioner and three exhibits were admitted into evidence.
FINDINGS OF FACT
In the original corporate income tax report submitted by Florida Power Corporation for the 1973 tax year the tax was computed using the federal income tax base. This included various depreciation methods and schedules in which accelerated depreciation had been claimed for federal tax purposes by Petitioner in years prior to 1972 and the initiation of the Florida Corporate Income Tax Law.
By using accelerated depreciation schedules authorized by the federal tax laws, higher depreciation is allowed in the early years of an asset's useful life, leaving a lesser amount of depreciation to be charged off for tax purposes in the latter years of an asset's life. Essentially, Petitioner here contends that depreciable assets acquired prior to the effective date of the Florida Corporate Income Tax law were depreciated on accelerated schedules for federal tax purposes, but upon the effective date of the Florida Corporate Income Tax Law had value in excess of that shown on the federal tax schedule. By requiring taxpayers to use the same depreciation schedules for Florida taxes that are required for federal taxes Petitioner contends it is being penalized for the accelerated depreciation taken before the Florida income tax became constitutional. As an example of Petitioner's position it may be assumed that a depreciable asset was acquired for $100,000 with a useful life of 10 years, three years before the Florida Income Tax Law was passed. Also assume that during this three-year period from acquisition a double declining balance depreciation was taken for computing federal income taxes. Depreciation taken for the first year would be $20,000, for the second year $16,000 and for the third year $12,800, leaving a basis for further depreciation of $41,200 for this asset with seven years useful life remaining. For federal tax purposes Petitioner takes depreciation each year based upon initial cost less accumulated depreciation. Because this value decreased rapidly for the first three years in the assumed example and the excess depreciation thereby generated was not usable in reducing Florida taxes, Petitioner contends it is discriminated against in being required to, in effect, use the book value for federal tax purposes in computing its Florida income tax.
Petitioner presented additional examples of reported income for federal income tax purposes which it claims should be exempt from Florida Income Tax. The specific deductions from which the $619,697 refund was computed were not broken down to show how much resulted from the accelerated depreciation schedules which commences prior to January 1, 1972, and how much was derived from these additional examples, some of which were given simply as an example of deferring income for tax purposes.
Prior to January 1, 1972, Petitioner purchased some of its bonds prior to maturity and at a discount. As an example if Petitioner purchases $1,000,000 face value of these bonds for $800,000, it has realized a $200,000 gain which it must report as income for federal income tax purposes. These same federal tax rules allow Petitioner to elect to pay the income tax in the year received or spread it equally over the succeeding ten year period. Petitioner elected to spread the income over the succeeding ten year period and each year add $20,000 to its reported income for federal income tax purposes. Since the income was realized before January 1, 1972, Petitioner contends this is not subject to federal tax purposes.
With respect to overhead during construction of depreciable assets the taxpayer is allowed to charge these costs off as an expense in the year incurred or capitalize these expenses. If the taxpayer elects to capitalize these expenses they are added to the cost of the constructed asset and recovered as depreciation as the asset is used. Petitioner elected to charge these expenses in the year incurred rather than capitalize them. Had they been capitalized originally, Petitioner would, in 1973, have been entitled to recover these costs in its depreciation of the asset. In its amended return it seeks to treat these costs as if they had been capitalized rather than expenses prior to January 1, 1972.
Although apparently not involved in the amended return, Petitioner also presented an example where changes in accounting procedures can result in a gain to the taxpayer which is treated as income to the taxpayer, which he may elect to spread over future years in equal increments until the total gain has been reported.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction over the parties and the subject matter of this hearing.
Constitutional authorization for income taxes is contained in Article VII, Section 5(b), Florida Constitution, which provides in pertinent part:
"No tax upon the income of . . . other than natural persons shall be levied by the state, or under its authority, in excess of 5% of net income, as defined by law. . . .
Chapter 220, Florida Statutes, the Florida Income Tax Code, contains the laws relating to income taxes in Florida
The legislative intent of the Florida Income Tax Code is contained in Section 220.02, Florida Statutes, which provides in pertinent part:
It is the intent of the Legislature that the tax levied by this Code shall be construed to be an excise or privilege tax measured by net income, and that said tax shall not be deemed or construed to be a property tax or a tax on property or a tax measured by the value of property for any purpose.
It is the intent of the Legislature that the income tax imposed by this code shall utilize, to the greatest extent possible, concepts of law which have been developed in connection with the income tax laws of the United States, in order to:
Minimize the expenses of the Department of Revenue and difficulties in administering this code;
Minimize the costs and difficulties of taxpayer compliance; and
Maximize, for both revenue and statistical purposes, the sharing of information between the state and the Federal government.
It is the intent of the Legislature that the tax imposed by this code shall be prospective in effect only. Consistent with this intention and the intent expressed in subsection (3), it is hereby declared to be
the intent of the Legislature that:
"Income," for purposes of this code, including gains from the sale, exchange, or other disposition of property,
shall be deemed to be created for Florida income tax purposes at such time as said income is realized for federal income purposes;
No accretion of value, no accrual of gain, and no acquisition of a right to receive or accrue income which has occurred or been generated prior to November 2, 1971, shall be deemed to be "property," or an interest in property, for any purpose under this code; and
All income realized for federal income tax purposes after November 2, 1971, shall be subject to taxation in full by this state and shall be taxed in the manner and to the extent provided in this code.
Section 220.13(2) provides generally that a taxpayer's taxable income shall mean taxable income as defined in Section 63 of the Internal Revenue Code and properly reportable for federal income tax purposes for the taxable year.
Section 220.42 in establishing methods of accounting provides in pertinent part:
For purposes of this code, a taxpayer's method of accounting shall be the same as
such taxpayer's method of accounting for federal income tax purposes, except as provided in subsection (3). If no method of accounting has been regularly used by a taxpayer, net income for purposes of this code shall be computed by such method as in the opinion of the department fairly reflects income.
If a taxpayer's method of accounting is changed for federal income tax purposes, the taxpayer's method of accounting for purposes of this code shall be similarly changed.
Finally, Section 220.43(1) provides:
To the extent not inconsistent with the provisions of this code or forms or regulations prescribed by the department, each taxpayer making a return under this code shall take into account the items of income, deduction, and exclusion on such return in the same manner and amounts as reflected in such taxpayer's federal income tax return for the same taxable year.
Throughout Chapter 220, reference is made to the federal income tax laws as a base for computing income taxes owed to Florida. The above quoted statutory provisions provide that depreciation schedules used for federal income tax purposes shall be used for computing Florida income tax, and reportable income for federal tax purposes (with certain additions thereto) shall form the base for computing Florida income taxes.
Both Petitioner and Respondent have cited cases wherein the courts have recently construed the provisions of the Florida Income Tax laws. In Department of Revenue v. Leadership Housing, Inc., 343 So.2d 611 (Fla.. 1977), the court considered appreciation in value of property prior to the passage of the Florida Income Tax laws and whether such appreciation could be taxed when the property was sold subsequent to January 1, 1972. The court held that capital appreciation is not income until it has been separated from its capital. The court stated at 615:
We believe the realization doctrine is the fairest for all taxpayers.
* * *
In summary, we hold that appreciation becomes income only upon the sale, exchange, or other disposition of the capital asset together with the accretions thereto, and that such realized gain is income in the year of disposition regardless of when it occurred.
Following the mirror image of this decision, the gain realized by Petitioner on the purchase of its bonds before January 1, 1972, and which it elected to spread over a ten (10) year period for federal income tax purposes, is not income realized for Florida income tax purposes. See also S.R.H. Corp.
v. Department of Revenue, Fla.Sup.Ct. Case No. 52,491, Opinion filed June 20, 1978; Department of Revenue v. Cone, Wagner, Nugent, Johnson & McKeown, P.A.,
349 So.2d 1240 (Fla. 4 DCA 1977); and Clearwater Federal Savings & Loan Association v. Department of Revenue, 350 So.2d 1134 (Fla. 2DCA 1977).
The primary consideration here involved is how to treat depreciation which Petitioner took on an accelerated basis before January 1, 1972. Although in accounting parlance depreciation is normally referred to as an expense, a necessary and proper cost of doing business, and hence deductible in arriving at taxable income, depreciation may more accurately be termed a return of capital used to purchase assets used in the production of income. The cost of a capital asset used for the production of income may be offset against income by the taxpayer up to 100% of the cost of the asset. Once 100% of the asset has been recovered through depreciation, then when the asset is disposed of by sale or salvage, the amount received from the sale is treated as income.
Federal tax allowing accelerated depreciation serve the purpose of allowing the taxpayer to sooner recoup the cost of his investment in assets used to produce income.
Here Petitioner recovered as depreciation part of this capital at an accelerated rate prior to January 1, 1972. When the Florida Income Tax law came into being January 1, 1972, the only "depreciation" which remained to be recovered from these assets was the cost of the asset less the capital recovered as depreciation prior to January 1, 1972.
Depreciation is neither income nor the reciprocal of income. While the tax laws allow depreciation to be deducted from earnings in determining taxable income, this deduction is available only until the cost of the asset has been recovered. No income was realized by the taxpayer as a result of accelerated depreciation taken before January 1, 1972. While the higher expenses allowed Petitioner, which resulted from the accelerated depreciation
served to reduce its federal income tax before January 1, 1972, still no income was realized.
From the foregoing it is concluded that the Florida income tax is based upon the federal income tax base which includes all accelerated depreciation methods employed by the taxpayer for the year involved without regard to tax measures used in prior years. Income actually realized prior to January 1, 1972, from the purchase of Petitioner's bonds at a discount is not income for Florida Income Tax purposes even though it is reported as income on the taxpayer's federal return. It is therefore
RECOMMENDED that the petition for refund of corporate income taxes for 1973 by Florida Power Corporation resulting from recomputation of depreciation schedules be denied and that the portion of the refund request pertaining to income actually realized from purchase of bonds at a discount be granted.
DONE AND ENTERED this 12th day of December 1978 in Tallahassee, Florida.
K. N. AYERS Hearing Officer
Division of Administrative Hearings Collins Building, Room 101 Tallahassee, Florida 32399-1550
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 12th day of December 1978.
COPIES FURNISHED:
Blair W. Clark, Esquire Richard W. Neiser, Esquire Post Office Box 14042
St. Petersburg, Florida 33733
Wilson Crump, II, Esquire Assistant Attorney General Department of Legal Affairs The Capitol, Room 1502 Tallahassee, Florida 32304
=================================================================
AGENCY FINAL ORDER
=================================================================
STATE OF FLORIDA OFFICE OF THE COMPTROLLER
FLORIDA POWER CORPORATION,
Petitioner,
vs. CASE NO. 78-1227
GERALD A. LEWIS, et al.,
Respondent.
/
FINAL ORDER
Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, K. N. Ayers, held a public hearing in the above styled case on October 20, 1978, at Tampa, Florida.
APPEARANCES
For Petitioner: Blair W. Clark, Esquire
Richard W. Neiser, Esquire Post Office Box 14042
St. Petersburg, Florida 33733
For Respondent: E. Wilson Crump, II, Esquire
Assistant Attorney General Department of Legal Affairs The Capitol, Room 1502 Tallahassee, Florida 32304
By petition filed July 5, 1978, the Florida Power Corporation, Petitioner, seeks refund of $619,697 in corporate income taxes paid in 1973. As grounds therefor it is alleged that the original income tax return was in error and that the amended tax return in which depreciation was recalculated showed the correct amount of corporate income taxes due and the difference between the amount of corporate taxes paid and the amount owed according to the amended return should be refunded. Petitioner's contention that denial of refund violates the Florida Constitution is an issue beyond the jurisdiction of the Office of the Comptroller.
There is no dispute regarding the facts in this case. One witness was called by Petitioner and three exhibits were admitted into evidence. The Recommended Order of the Hearing Officer is modified to include the finding that the evidence did not establish the amount of the debt retired before January 1, 1972. Accordingly, the Respondent's Exceptions are granted and its Proposed Order is adopted.
FINDINGS OF FACT
In the original corporate income tax report submitted by Florida Power Corporation for the 1973 tax year the tax was computed using the federal income tax base. This included various depreciation methods and schedules in which accelerated depreciation had been claimed for federal tax purposes by Petitioner in years prior to 1972 and the initiation of the Florida Corporate Income Tax Law.
By using accelerated depreciation schedules authorized by the federal tax laws, higher depreciation is allowed in the early years of an asset's useful life, leaving a lesser amount of depreciation to be charged off for tax purposes in the latter years of an asset's life. Essentially, Petitioner here contends that depreciable assets acquired prior to the effective date of the Florida Corporate Income Tax law were depreciated on accelerated schedules for federal tax purposes, but upon the effective date of the Florida Corporate Income Tax Law had value in excess of that shown on the federal tax schedule. By requiring taxpayers to use the same depreciation schedules for Florida taxes that are required for federal taxes Petitioner contends it is being penalized for the accelerated depreciation taken before the Florida income tax became constitutional. As an example of Petitioner's position it may be assumed that a depreciable asset was acquired for $100,000 with a useful life of 10 years, three years before the Florida Income Tax Law was passed. Also assume that during this three-year period from acquisition a double declining balance depreciation was taken for computing federal income taxes. Depreciation taken for the first year would be $20,000, for the second year $16,000 and for the third year $12,800, leaving a basis for further depreciation of $41,200 for this asset with seven years useful life remaining. For federal tax purposes Petitioner takes depreciation each year based upon initial cost less accumulated depreciation. Because this value decreased rapidly for the first three years in the assumed example and the excess depreciation thereby generated was not usable in reducing Florida taxes, Petitioner contends it is discriminated against in being required to, in effect, use the book value for federal tax purposes in computing its Florida income tax.
Petitioner presented additional examples of reported income for federal income tax purposes which it claims should be exempt from Florida Income Tax. The specific deductions from which the $619,697 refund was computed were not broken down to show how much resulted from the accelerated depreciation schedules which commences prior to January 1, 1972, and how much was derived from these additional examples, some of which were given simply as an example of deferring income for tax purposes.
Prior to January 1, 1972, Petitioner purchased some of its bonds prior to maturity and at a discount. As an example if Petitioner purchases $1,000,000 face value of these bonds for $800,000, it has realized a $200,000 gain which it must report as income for federal income tax purposes. These same federal tax rules allow Petitioner to elect to pay the income tax in the year received or spread it over the remaining time that the related assets which were acquired with the debt are depreciated, or until they are sold or disposed of. This is accomplished by reducing the basis of the asset for federal tax purposes by the amount of the realized gain resulting in a reduction of depreciation deductions in subsequent years, or additional gain if the asset is disposed of before being fully depreciated. (Transcript of Testimony pp 10, 31) Petitioner elected this treatment of the gains resulting from its debt discharge. Since the income was realized before January 1, 1972, Petitioner contends this is not subject to tax for Florida tax purposes. However, the returns placed into evidence do not
reveal how much of Petitioner's refund claim is based on debt retired before January 1, 1972. The only witness to testify, Mr. William Edward Parker, testified that deferred recognition on gain realized from reacquired debt represented part of the refund claim, but he did not testify how much. Thus, there was no competent, substantial evidence presented on the record to indicate just how much gain realized for federal purposes prior to January 1, 1972, by reason of reacquired bonds had in fact been recognized on Petitioner's 1973 federal tax return.
With respect to overhead during construction of depreciable assets the taxpayer is allowed to charge these costs off as an expense in the year incurred or capitalize these expenses. If the taxpayer elects to capitalize these expenses they are added to the cost of the constructed asset and recovered as depreciation as the asset is used. Petitioner elected to charge these expenses in the year incurred rather than capitalize them. Had they been capitalized originally, Petitioner would, in 1973, have been entitled to recover these costs in its depreciation of the asset. In its amended return it seeks to treat these costs as if they had been capitalized rather than expenses prior to January 1, 1972.
Although apparently not involved in the amended return, Petitioner also presented an example where changes in accounting procedures can result in a gain to the taxpayer which is treated as income to the taxpayer, which he may elect to spread over future years in equal increments until the total gain has been reported.
CONCLUSIONS OF LAW
Constitutional authorization for income taxes is contained in Article VII, Section 5(b), Florida Constitution, which provides in pertinent part:
"No tax upon the income of . . . other than natural persons shall be levied by the state, or under its authority, in excess of 5% of net income, as defined by law. . . .
Chapter 220, Florida Statutes, the Florida Income Tax Code, contains the laws relating to income taxes in Florida.
The legislative intent of the Florida Income Tax Code is contained in Section 220.02, Florida Statutes, which provides in pertinent part:
It is the intent of the Legislature that the tax levied by this Code shall be construed to be an excise or privilege tax measured by net income, and that said tax shall not be deemed or construed to be a property tax or a tax on property or a tax measured by the value of property for any purpose.
It is the intent of the Legislature that the income tax imposed by this code shall utilize, to the greatest extent possible, concepts of law which have been developed in connection with the income tax laws of the United States, in order to:
Minimize the expenses of the
Department of Revenue and difficulties in administering this code;
Minimize the costs and difficulties of taxpayer compliance; and
Maximize, for both revenue and statistical purposes, the sharing of information between the state and the Federal government.
It is the intent of the Legislature that the tax imposed by this code shall be prospective in effect only. Consistent with this intention and the intent expressed in subsection (3), it is hereby declared to be
the intent of the Legislature that:
"Income," for purposes of this code, including gains from the sale, exchange, or other disposition of property, shall be deemed to be created for Florida income tax purposes at such time as said income is realized for federal income purposes;
No accretion of value, no accrual of gain, and no acquisition of a right to receive or accrue income which has occurred or been generated prior to November 2, 1971, shall be deemed to be "property," or an interest in property, for any purpose under this code; and
All income realized for federal income tax purposes after November 2, 1971, shall be subject to taxation in full by this state and shall be taxed in the manner and to the extent provided in this code.
Section 220.13(2) provides generally that a taxpayer's taxable income shall mean taxable income as defined in Section 63 of the Internal Revenue Code and properly reportable for federal income tax purposes for the taxable year.
Section 220.42 in establishing methods of accounting provides in pertinent part:
For purposes of this code, a taxpayer's method of accounting shall be the same as such taxpayer's method of accounting for federal income tax purposes, except as provided in subsection (3). If no method of accounting has been regularly used by a taxpayer, net income for purposes of this code shall be computed by such method as in the opinion of the department fairly reflects income.
If a taxpayer's method of accounting is changed for federal income tax purposes, the taxpayer's method of accounting for purposes of this code shall be similarly changed.
Finally, Section 220.43(1) provides:
To the extent not inconsistent with the provisions of this code or forms or regulations prescribed by the department, each taxpayer making a return under this code shall take into account the items of income, deduction, and exclusion on such return in the same manner and amounts as reflected in such taxpayer's federal income tax return for the same taxable year.
Throughout Chapter 220, reference is made to the federal income tax laws as a base for computing income taxes owed to Florida. The above quoted statutory provisions provide that depreciation schedules used for federal income tax purposes shall be used for computing Florida income tax, and reportable income for federal tax purposes (with certain additions thereto) shall form the base for computing Florida income taxes.
Both Petitioner and Respondent have cited cases wherein the courts have recently construed the provisions of the Florida Income Tax laws. In Department of Revenue v. Leadership Housing, Inc., 343 So.2d 611 (Fla. 1977), the court considered appreciation in value of property prior to the passage of the Florida Income Tax laws and whether such appreciation could be taxed when the property was sold subsequent to January 1, 1972. The court held that capital appreciation is not income until it has been separated from its capital. The court stated at 615:
We believe the realization doctrine is the fairest for all taxpayers.
* * *
In summary, we hold that appreciation becomes income only upon the sale, exchange, or other disposition of the capital asset together with the accretions thereto, and that such realized gain is income in the year of disposition regardless of when it occurred.
Following the mirror image of this decision, the gain realized by Petitioner on the purchase of its bonds before January 1, 1972, and which it elected to spread over a ten (10) year period for federal income tax purposes, is not income realized for Florida income tax purposes. See also S.R.H. Corp.
v. Department of Revenue, Fla.Sup.Ct. Case No. 52,491, Opinion filed June 20, 1978; Department of Revenue v. Cone, Wagner, Nugent, Johnson & McKeown, P.A.,
349 So.2d 1240 (Fla. 4 DCA 1977); and Clearwater Federal Savings & Loan Association v. Department of Revenue, 350 So.2d 1134 (Fla. 2 DCA 1977).
The primary consideration here involved is how to treat depreciation which Petitioner took on an accelerated basis before January 1, 1972. Although in accounting parlance depreciation is normally referred to as an expense, a necessary and proper cost of doing business, and hence deductible in arriving at taxable income, depreciation may more accurately be termed a return of capital used to purchase assets used in the production of income. The cost of a capital asset used for the production of income may be offset against income by the taxpayer up to 100% of the cost of the asset. Once 100% of the asset has been recovered through depreciation, then when the asset is disposed of by sale or salvage, the amount received from the sale is treated as income.
Federal tax allowing accelerated depreciation serve the purpose of allowing the taxpayer to sooner recoup the cost of his investment in assets used to produce income.
Here Petitioner recovered as depreciation part of this capital at an accelerated rate prior to January 1, 1972. When the Florida Income Tax law came into being January 1, 1972, the only "depreciation" which remained to be recovered from these assets was the cost of the asset less the capital recovered as depreciation prior to January 1, 1972.
Depreciation is neither income nor the reciprocal of income. While the tax laws allow depreciation to be deducted from earnings in determining taxable income, this deduction is available only until the cost of the asset has been recovered. No income was realized by the taxpayer as a result of accelerated depreciation taken before January 1, 1972. While the higher expenses allowed Petitioner, which resulted from the accelerated depreciation served to reduce its federal income tax before January 1, 1972, still no income was realized.
From the foregoing it is concluded that the Florida income tax is based upon the federal income tax base which includes all accelerated depreciation methods employed by the taxpayer for the year involved without regard to tax measures used in prior years. Income actually realized prior to January 1, 1972, from the purchase of Petitioner's bonds at a discount is not income for Florida Income Tax purposes even though it is reported as income on the taxpayer's federal return.
ORDER
Based on the foregoing Findings of Fact and Conclusions of Law, the Petitioner's request for refund of corporate income taxes for 1973 resulting from recomputation of depreciation schedules is denied and that the portion of the refund request pertaining to income actually realized from purchase of bonds at a discount is denied for failure of Petitioner to establish the amount of refund pertaining to this point.
DONE AND ENTERED this 12th day of March, 1979, in Tallahassee, Florida.
GERALD A. LEWIS, Comptroller
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent by regular U.S. Mail to Blair W. Clark, Esquire, and Richard W. Neiser, Esquire, Post Office Box 14042, St. Petersburg, Florida, 33733 and E. Wilson Crump, II, Esquire, Assistant Attorney General, Department of Legal Affairs, The Capitol, Room 1502, Tallahassee, Florida, 32301 this 12th day of March, 1979.
KARLYN ANNE LOUCKS
Assistant General Counsel
Docket for Case No: 78-001227
Orders for Case No: 78-001227
| Issue Date |
Document |
Summary |
|
Mar. 12, 1979 |
Agency Final Order
|
|
|
Dec. 12, 1978 |
Recommended Order
|
Prior year's income is not income for Florida tax purposes even though it is reported as income on the taxpayer's federal return. Recommend refund.
|
