Richard C. Call
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Richard C. Call focuses his practice on state and local tax litigation before administrative and judicial bodies, at all levels and in multiple states, with respect to income, franchise, gross receipts, and sales and use taxes. He also advises clients on the state and local tax consequences of business restructurings, as well as the impact of new state legislation on current business operations. Read Richard C. Call's full bio.
By Richard C. Call and Scott M. Susko on May 14, 2015
Posted In Allocation/Apportionment, Constitutional Issues, Massachusetts, Nexus, Procedure
Allied Domecq Spirits & Wines USA, Inc. v. Comm’r of Revenue, 85 Mass. App. Ct. 1125 (2014) In a unique case, the Massachusetts Appeals Court affirmed a ruling of the Appellate Tax Board (ATB) that two corporations could not be combined for corporation excise tax purposes for 1996 through 2004. The distinctive aspect of this...
By Richard C. Call on Dec 16, 2014
Posted In Interest and Penalties, New Jersey
The Supreme Court of New Jersey recently affirmed a decision that amnesty and late‑filing penalties did not apply to the taxpayers in United Parcel Serv. Gen. Servs. Co. v. Dir., Div. of Taxation, No. 072421 (N.J. Dec. 4, 2014). In all, approximately $2 million in penalties and related interest were abated. The primary substantive issue...
By Arthur R. Rosen and Richard C. Call on Oct 31, 2014
Posted In Income Tax, New Jersey, Sales Tax, Tax Base
In a Corporation Business Tax (CBT) case, PPL Electric Utilities Corporation v. Director, Division of Taxation, Dkt. No. 000005-2011 (N.J. Tax. Ct. Oct. 2, 2014), the Tax Court of New Jersey found for the taxpayer and held that the Pennsylvania Gross Receipts Tax and Pennsylvania Capital Stock Tax were not required to be added back in...
New Jersey Division of Taxation’s 2014 Tax Resolution Initiative – Not To Be Confused With An Amnesty
By Arthur R. Rosen and Richard C. Call on Oct 30, 2014
Posted In Income Tax, New Jersey, Property Tax, Tax Base
The New Jersey Division of Taxation (Division) is trying to help taxpayers resolve unpaid tax liabilities for tax periods 2005 through 2013. Through November 17, 2014, the Division is offering taxpayers that pay all tax and interest for the applicable periods a waiver of most penalties (but not penalties related to the 2009 amnesty) and any...
By Catherine A. Battin, Richard C. Call and Scott M. Susko on Aug 4, 2014
Posted In Massachusetts, Procedure
The Massachusetts Department of Revenue’s new Early Mediation Program (EMP) is off to a very promising start. The EMP expedites the normal appeals process and offers hope to taxpayers that desire to resolve tax disputes without prolonged litigation. The Department indicated at a recent Boston Bar Association meeting that eight of the first 11 cases...