State and Local Taxation

Interpretation of the Tax Amnesty Program in the City of Richmond

Papers about tax amnesty and gavel in a court.

On April 2, 2020, the Supreme Court of Virginia issued an unpublished opinion in HRIP Miller & Rhoads Acquisition, LLC v. City of Richmond. This case concerned the applicability of a tax amnesty program in the City of Richmond to the taxpayer; more specifically whether a real estate tax payment was both “owed” and “delinquent” per the tax amnesty ordinance and therefore eligible for the tax amnesty program. Based on its interpretation of the ordinance, the city determined that the taxpayer was ineligible for the tax amnesty program. The Circuit Court of the City of Richmond agreed and dismissed the case. The Supreme Court of Virginia overruled and remanded the case back to the circuit court.

This opinion relied on previously established rules of statutory interpretation and did not establish a new rule or produce an interpretation of a complicated ordinance. It is likely that is why this opinion is unpublished.

Christian Tennant is a Virginia tax attorney and former employee of the Virginia Department of Taxation. Mr. Tennant regularly speaks and writes on Virginia taxation. In his private practice he advises and represents businesses and individuals on a range of tax matters.

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