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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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R


465.0000 Remedies of Taxpayers

Annotation 465.0012

(a) Redeterminations


465.0012 Interested Party—No Right to Overpayment. A person permitted to file a petition as an "interested party" under section 6561 is not necessarily entitled to any amounts ultimately determined to have been overpaid. For example, if a fully-paid determination is redetermined to zero, the interested party filing the petition would normally not be issued a refund of the amounts overpaid. To do so would be to determine that the interested party had the right to the overpayment rather than just a direct interest in the determination. The only conclusion made when the interested party was permitted to file the petition was that he/she had a direct interest in the matter. 10/2/89.