97-1248

WITHHOLDING

Signed 11/25/97

 

BEFORE THE UTAH STATE TAX COMMISSION

____________________________________

 

COMPANY A )

)

:

Petitioner, ) DECISION

:

v. )

:

COLLECTION DIVISION OF THE ) Appeal No. 97-1248

UTAH STATE TAX COMMISSION, :

STATE OF UTAH, ) Account No. #####

:

Respondent. ) Tax Type: Withholding Tax

 

_____________________________________

 

IMPORTANT NOTICE: On October 7, 1997 the Utah Supreme Court, in Evans and Sutherland Computer Corp v. Utah State Tax Commission, invalidated the informal adjudicative process by disallowing trial de novo to the District Court. Therefore, your appeal is now being processed as a formal adjudicative proceeding. Under this process, you are entitled to an additional right. Utah Law allows for an Initial Hearing before the matter is heard on the record in a formal proceeding. Therefore, the hearing held in this matter will constitute the Initial Hearing. Please note in the body of the decision your right to, and the method of request for, a formal hearing.

 

STATEMENT OF CASE

This matter came before the Utah State Tax Commission pursuant to the provisions of Utah Code Ann. '59-1-502.5. An Initial Hearing was held on September 29, 1997. Gail S. Reich, Administrative Law Judge, heard the matter for and on behalf of the Commission. Present and representing Petitioner was PETITIONERS REP.. Present and representing Respondent were RESPONDENT REP. and RESPONDENT REP., of the Auditing Division.

Based upon the evidence in the file and presented at the hearing, the Commission makes its:


FINDINGS

This appeal involves a 10% penalty imposed for failure to reconcile W-2's with annual reconciliation regarding the 1994 withholding tax. The penalty imposed was approximately $$$$$. Petitioner is appealing, requesting the penalty be waived. The record indicates that this constitutes first time error for the Petitioner on this account. Tax Commission guidelines indicate that first time error is sufficient grounds to justify waiver of the imposition of a penalty.

APPLICABLE LAW

The Tax Commission is granted the authority to waive, reduce, or compromise penalties and interest upon a showing of reasonable cause. (Utah Code Ann. '59-1-401(10).)

DECISION AND ORDER

Based upon the foregoing, it has been determined that sufficient cause does exist to waive the penalty associated with the period in issue. It is so ordered.

This Decision does not limit a party's right to a Formal Hearing. Any party to this case may file a written request within thirty (30) days of the date of this decision to proceed to a Formal Hearing. Such a request shall be mailed to the address listed below and must include the Petitioner's name, address, and appeal number:


Utah State Tax Commission

Appeals Division

210 North 1950 West

Salt Lake City, Utah 84134

 

Failure to request a Formal Hearing will preclude any further administrative action or appeal rights in this matter.

DATED this 25 day of NOVEMBER, 1997.

BY ORDER OF THE UTAH STATE TAX COMMISSION.

 

_____________________

Gail S. Reich

Administrative Law Judge

 

The agency has reviewed this case and the undersigned concur in this decision.

DATED this 25 day of NOVEMBER, 1997.

BY ORDER OF THE UTAH STATE TAX COMMISSION.

 

W. Val Oveson Richard B. McKeown

Chairman Commissioner

 

Joe B. Pacheco Pam Hendrickson

Commissioner Commissioner

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