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On April 2, 2020, the Supreme Court of Virginia issued an unpublished opinion in HRIP Miller & Rhoads Acquisition, LLC v. City of Richmond.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 It is likely that is why this opinion is unpublished.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.

Contact Us

  • This field is for validation purposes and should be left unchanged.

Tax Law Blog

2020 Virginia Department…
October 9th, 2020
On its website, the Virginia Department of Taxation has released several rulings and appeal decisions. Due to this crazy year and some personnel changes at the Virginia Department of Taxation, the rulings and appeal decisions have been released in ba…
The Saga of International…
September 18th, 2020
What has been happening between International Paper Company and Isle of Wight County? The dispute is not over but the Supreme Court of Virginia has weighed in.
BPOL Tax and Internet Tax…
August 24th, 2020
Previously, the opinion entered in Bd. of Supervisors v. Caxcom, LLC, Case no. CL-2019-5800 by the Circuit Court of Fairfax County determined that the Internet Tax Freedom Act applies to the BPOL tax. This month two similar opinions have been entered…

Read More Blog Entries