(a) Definition. An "opinion of the Tax Administrator" means an opinion issued under this section with respect to prospective City income tax liability; it does not include ordinary correspondence of the Tax Administrator.
(b) Taxpayer's Request for an Opinion of the Tax Administrator. A taxpayer may submit a written request for an opinion of the Tax Administrator in accordance with the Rules and Regulations.
(c) Effect of Taxpayer Misrepresentation on Opinion of the Tax Administrator.
(1) A taxpayer is not relieved of tax liability for any activity or transaction related to a request for an opinion that contained any misrepresentation or omission of one or more material facts.
(2) If the taxpayer knowingly has misrepresented the pertinent facts or omitted material facts with intent to defraud the City in order to obtain a more favorable opinion, the taxpayer may be in violation of Section 881.17 of this Chapter.
(d) Right of the Tax Administrator to Refuse to Issue Opinion. The Tax Administrator may refuse to offer an opinion on any request received under this section. Such refusal is not subject to appeal.
(e) Binding only to Taxpayer Who Requested Opinion. An opinion of the Tax Administrator binds the Tax Administrator only with respect to the taxpayer for whom the opinion was prepared and does not bind the Tax Administrator of any other municipal corporation.
(f) No Appeals. An opinion of the Tax Administrator issued under this section is not subject to appeal.
(Source: ORC 718.38)
(Ord. 2020-10. Adopted 04/23/20)