As a result of a change in Pennsylvania law and state computer systems limitations, there have been an increasing number of occurrences in which the Pennsylvania Department of Revenue has issued corporate tax assessments, but taxpayers have not received them. The concern for taxpayers is that the 90-day appeal window may close long before the taxpayer finds out an assessment was issued.
It may be possible to obtain a new assessment with a new mailing date, which would re-start the 90-day appeal period. However, the practical problem for taxpayers is that it is difficult to request the reissuance of an assessment that they don't know about. One way for a taxpayer to combat this situation is to proactively monitor their Pennsylvania tax accounts. This can be done by regularly requesting, and carefully reviewing, the Department's accounting ledger for your company's tax accounts.
Our experience has been that many Pennsylvania taxpayers are not taking this step, either because they are not aware that these accounting ledgers are available from the Department, or because the accounting ledgers are not presented in a taxpayer-friendly format, making them very difficult to review and understand. As a result, taxpayers are missing out on the wealth of information contained in these accounting ledgers. For example, it is not uncommon for taxpayers to find old tax liabilities and, more importantly in this economic environment, significant tax overpayments of which they were unaware.
We recommend that if you have not reviewed your Pennsylvania tax ledger in a while (or ever), now is the time to start regularly reviewing it to avoid missing appeal deadlines and uncover misplaced tax overpayments.