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(E) No civil action to recover the City income tax or related penalties or interest shall be brought during <br />either of the following time periods: <br />(1) The period during which a taxpayer has a right to appeal the imposition of that tax or interest or those <br />penalties; <br />(2) The period during which an appeal related to the imposition of that tax or interest or those penalties <br />is pending. <br />WITWItl.1") W <br />(A) At or before the commencement of an audit, the Tax Administrator shall provide to the taxpayer a <br />written description ofthe roles of the Tax Administrator and of the taxpayer during the audit and a statement <br />of the taxpayer's rights, including any right to obtain a refund of an overpayment of a tax. At or before the <br />commencement of an audit, the Tax Administrator shall inform the taxpayer when the audit is considered <br />to have commenced. <br />(B) Except in cases involving suspected criminal activity, the Tax Administrator shall conduct an audit of <br />a taxpayer during regular business hours and after providing reasonable notice to the taxpayer. A taxpayer <br />who is unable to comply with a proposed time for an audit on the grounds that the proposed time would <br />cause inconvenience or hardship must offer reasonable alternative dates for the audit. <br />(C) At all stages of an audit by the Tax Administrator, a taxpayer is entitled to be assisted or represented <br />by an attorney, accountant, bookkeeper, or other tax practitioner. The Tax Administrator shall prescribe a <br />form by which a taxpayer may designate such a person to assist or represent the taxpayer in the conduct of <br />any proceedings resulting from actions by the Tax Administrator. If a taxpayer has not submitted such a <br />form, the Tax Administrator may accept other evidence, as the Tax Administrator considers appropriate, <br />that a person is the authorized representative of a taxpayer. <br />A taxpayer may refuse to answer any questions asked by the person conducting an audit until the taxpayer <br />has an opportunity to consult with the taxpayer's attorney, accountant, bookkeeper, or other tax practitioner. <br />This division does not authorize the practice of law by a person who is not an attorney. <br />(D) A taxpayer may record, electronically or otherwise, the audit examination. <br />(E) The failure of the Tax Administrator to comply with a provision of this section shall neither excuse a <br />taxpayer from payment of any taxes owed by the taxpayer nor cure any procedural defect in a taxpayer's <br />case. <br />(F) If the Tax Administrator fails to substantially comply with the provisions of this section, the Tax <br />Administrator, upon application by the taxpayer, shall excuse the taxpayer from penalties and interest <br />1501.14 SERVICE OF ASSESSMENT. <br />(A) As used in this section: <br />(1) "Last known address" means the address the Tax Administrator has at the time a document is <br />originally sent by certified mail, or any address the Tax Administrator can ascertain using reasonable means <br />HE <br />