Can an insurer exclude bonuses from the Florida insurance premium tax salary-credit calculation based on TAA 04B8-001?

Plain-English summary

Do not rely on the original holding in this TAA. The Florida Department of Revenue placed a warning at the beginning of the official PDF: “This Technical Assistance Advisement is no longer correct.” The notice directs readers to Auto-Owners Insurance Company v. DOR, Case No. 08-CA-1938 (2d Cir. Ct. Sept. 1, 2009), for more information.

The rest of the document preserves the Department's superseded 2004 analysis. It originally concluded that annual management bonuses paid to Florida employees were not “salary” for the insurance premium tax salary credit under section 624.509, even though the insurer included salary and bonuses in its Florida unemployment-compensation returns.

What the 2004 ruling originally said

The insurer paid Florida employees base salary and annual management bonuses based on prior-year corporate, business-group, and business-unit performance. The bonus plan defined salary as base annual salary and defined a bonus as an award based on performance measures.

Section 624.509(5), as quoted in the TAA, allowed a credit equal to 15% of salaries paid to qualifying Florida employees covered by Chapter 443. The original analysis drew a strict distinction between the statute's word “salaries” and the broader unemployment-compensation concept of “wages.” It reasoned that:

• The Legislature chose “salaries,” not “wages.”
• The bonus plan itself separately defined base salary and bonuses.
• Tax-credit statutes were strictly construed.
• A Taxpayer Information Publication using the word “wages” could not override the statute.

On that reasoning, the 2004 TAA denied inclusion of the bonuses in the credit calculation.

Why the historical answer cannot be used now

The Department's later warning is categorical: the TAA is “no longer correct.” The official document does not revise the body or state a replacement calculation; it points to the 2009 Auto-Owners circuit-court case instead.

Accordingly, this page records the former position for historical research but does not present the original “No” as current guidance. The Department's current Insurance Premium Tax Incentives page describes the salary credit at a high level and cites section 624.509 and Rule 12B-8.001, but the program page does not answer the bonus question in the text reviewed for this summary.

What this means for you

Insurance companies

Do not exclude or include bonuses solely from TAA 04B8-001. The Department itself has withdrawn the correctness of that ruling's analysis.

Payroll and insurance-tax teams

Preserve records showing base salary, bonuses, Florida employee location, Chapter 443 coverage, and how amounts appear in unemployment filings. Obtain current advice before computing the credit.

Researchers

The document remains useful for understanding the Department's former statutory interpretation, but every quotation from its holding should be labeled obsolete and paired with the official warning.

Common questions

Q: What did the TAA originally hold?
A: It said management bonuses were not salary and were excluded from the section 624.509 salary-credit calculation.

Q: Is that answer still valid?
A: The Department says no—the official PDF expressly states that the TAA is no longer correct.

Q: What later authority does the Department identify?
A: Auto-Owners Insurance Company v. DOR, Case No. 08-CA-1938 (2d Cir. Ct. Sept. 1, 2009).

Q: Does the warning itself provide the replacement calculation?
A: No. It identifies the later court case but does not rewrite the TAA's analysis.

Citations and references

• Fla. Stat. § 624.509(5)-(7) — salary credit against insurance premium tax and limitations
• Fla. Stat. §§ 443.036(44) and 443.1217(1) — unemployment-compensation wages
• Fla. Admin. Code r. 12B-8.001 — premium tax and salary-credit computation
• Fla. Admin. Code r. 12-11.013 — Taxpayer Information Publications are not controlling authority
• Auto-Owners Insurance Company v. Department of Revenue, Case No. 08-CA-1938 (Fla. 2d Cir. Ct. Sept. 1, 2009) — later case identified by the Department's warning

Source

• Landing page: Florida Tax Law Library
• Advisement: TAA 04B8-001
• Current program page: Florida Insurance Premium Tax Incentives

Original ruling text

This Technical Assistance Advisement is no longer correct.
Please see the court case Auto-Owners Insurance Company v.
DOR, Case No.08-CA-1938 (2nd Cir. Ct. September 1, 2009),
for more information.

SUMMARY
QUESTION: Are the Taxpayer's bonus payments to its
Florida employees, which are included in its Florida
unemployment compensation filings, included in the
salary tax credit calculation under section 624.509,
F.S.?
ANSWER - Based on Facts Below: No, the Taxpayer's
bonus payments to its Florida employees, which are
included in its Florida unemployment compensation
filings, are not included in the salary tax credit
calculation under section 624.509, F.S.

September 9, 2004

Re:

Technical Assistance Advisement 04B8-001
Insurance Premium Tax - Salary Tax Credit
Section 624.509, F.S.
XXX, hereinafter referred to as "A"

Dear :
This is the Department's response to XXX letter dated XX,
requesting a Technical Assistance Advisement on whether
bonuses, that are paid to "A's" employees and included in
"A's" unemployment filings with Florida, should be included
in the computation of the salary tax credit under section
624.509, F.S. This response to your request constitutes a
Technical Assistance Advisement under Chapter 12-11,
Florida Administrative Code, and is issued to you under the
authority of s. 213.22, Florida Statutes.
FACTS
"A" is domiciled in XXX, and is engaged in the insurance
business in a number of states, including the State of
Florida. "A" has employees that are located in Florida. "A"
compensates these employees on a salary basis. "A" also has
a management bonus program. "A" generally pays management
bonuses to eligible employees on an annual basis (usually
in March - based on prior year performance). "A" files
Florida unemployment compensation returns that include the
compensation (salary and bonuses) that "A" paid to its
Florida employees.

"A's" management bonus plan states that it is:
intended to provide financial rewards to eligible
employees for achieving performance expectations
based upon a combination of corporate measurers. The
[management bonus plan] is designed to allow business
groups and business units to focus on and reward
employees for the appropriate financial and/or
performance objectives. The [management bonus plan]
is aligned with corporate, business group and
business unit objectives and, ultimately,
performance.
"A's" management bonus plan defines "salary" as:
a participant's base annual salary as of December 31.
In cases where a participant's target bonus changes
during the year due to promotion or demotion, the
qualifying individual will receive a Bonus
calculation using the target Bonus and base salary
prior to the promotion and the target Bonus and base
salary on December 31, each on a pro rata share.
"A's" management bonus plan defines "bonus" as:
an award under the Plan based on satisfaction during
the Plan Period of the applicable Performance
Measures."
The term "Target Bonus" is defined as:
a "defined percentage of the Participant's base
salary."
The management bonus plan also provides that the "Company
will deduct the amounts required by law to be withheld for
federal, state and local income and employment taxes for
all Bonus payments."
The employees at issue in this request are not excluded
from the computation of the salary tax credit that is
provided in s. 624.509, F.S. The salary payments made by
"A" to these Florida employees are allowed to be used in
the computation of the salary tax credit provided in s.
624.509, F.S., and are not at issue in this request. The
only issue in this request is whether the bonus payments to
"A's" Florida employees should be included with the salary
in the computation of the salary tax credit under s.
624.509, F.S.
QUESTION
Are "A's" bonus payments to its Florida employees, which
are included in its Florida unemployment compensation

filings, included in the salary tax credit calculation
under section 624.509, F.S.?
LAW
Section 624.509(5), (6), and (7), F.S., state:
(5) There shall be allowed a credit against the net
tax imposed by this section equal to 15 percent of
the amount paid by the insurer in salaries to
employees located or based within this state and who
are covered by the provisions of chapter 443. For
purposes of this subsection:
(a) The term "salaries" does not include amounts paid
as commissions.
(b) The term "employees" does not include independent
contractors or any person whose duties require that
the person hold a valid license under the Florida
Insurance Code, except persons defined in s.
626.015(1), (15), and (17).
(c) The term "net tax" means the tax imposed by this
section after applying the calculations and credits
set forth in subsection (4).
(d) An affiliated group of corporations that created
a service company within its affiliated group on July
30, 2002, shall allocate the salary of each service
company employee covered by contracts with affiliated
group members to the companies for which the
employees perform services. The salary allocation is
based on the amount of time during the tax year that
the individual employee spends performing services or
otherwise working for each company over the total
amount of time the employee spends performing
services or otherwise working for all companies. The
total amount of salary allocated to an insurance
company within the affiliated group shall be included
as that insurer's employee salaries for purposes of
this section.

1. The term "affiliated group of corporations" means
   two or more corporations that are entirely owned by a
   single corporation and that constitute an affiliated
   group of corporations as defined in s. 1504(a) of the
   Internal Revenue Code.
2. The term "service company" means a separate
   corporation within the affiliated group of
   corporations whose employees provide services to
   affiliated group members and which are treated as
   service company employees for unemployment
   compensation and common law purposes. The holding

company of an affiliated group may not qualify as a
service company. An insurance company may not qualify
as a service company.

3. If an insurance company fails to substantiate,
   whether by means of adequate records or otherwise,
   its eligibility to claim the service company
   exception under this section, or its salary
   allocation under this section, no credit shall be
   allowed.
   (6) The total of the credit granted for the taxes
   paid by the insurer under chapters 220 and 221 and
   the credit granted by subsection (5) shall not exceed
   65 percent of the tax due under subsection (1) after
   deducting therefrom the taxes paid by the insurer
   under ss. 175.101 and 185.08 and any assessments
   pursuant to s. 440.51.
   (7) Credits and deductions against the tax imposed by
   this section shall be taken in the following order:
   deductions for assessments made pursuant to s.
   440.51; credits for taxes paid under ss. 175.101 and
   185.08; credits for income taxes paid under chapter
   220, the emergency excise tax paid under chapter 221
   and the credit allowed under subsection (5), as these
   credits are limited by subsection (6); all other
   available credits and deductions. (Emphasis Supplied)
   Rule 12B-8.001, F.A.C., states in part:
   (3)(a)1. The corporate income tax imposed under
   Chapter 220, F.S., and the emergency excise tax
   imposed under Chapter 221, F.S., which are, or should
   have been, filed and paid by an insurer shall
   discharge the liability for the insurance premium tax
   (IPT) imposed under s. 624.509, F.S., for the annual
   period in which such tax payments are or should have
   been made, to the extent of the maximum allowed. Any
   insurer issuing policies insuring against loss or
   damage from the risks of fire, tornado, and certain
   casualty lines may take a credit against gross
   premium receipts tax for the excise tax(es) imposed
   by s. 175.101, F.S., and s. 185.08, F.S.
   2.a. When an insurer is required to file a corporate
   income tax return where the due date and extended due
   date are in different calendar years, the due date,
   or the extended date when a valid extension of time
   is made of said Florida return, determines the annual
   period in which such tax payments should have been
   made.
   b. For example, a Florida corporate income tax return
   for tax year ending August 31, 2000, is due, without

extension, on December 1, 2000. Since the Florida
corporate income tax return is due on or before
December 31, 2000, the insurer should include the
amount of tax due on the return in computation of the
corporate income tax and emergency excise tax credit
on its 2000 insurance premium tax return, the 2000
DR-908, which is due March 1, 2001. If, however, the
insurer extended the due date of the Florida
corporate income tax return to June 1, 2001, and did
not file and pay the return on or before December 31,
2000, the amount of tax due on the return is included
in the computation of the corporate income tax and
emergency excise tax credit on its 2001 insurance
premium tax return, the 2001 DR-908, which is due
March 1, 2002.
(b) Salaries. Fifteen percent of the amount paid
after June 30, 1988, in salaries by the insurer to
employees located or based in Florida may be credited
against the net tax imposed by s. 624.509, F.S.

1. Salaries include only amounts paid directly to
   employees and do not include commissions paid to
   employees located or based in Florida.
2. Employees are those covered under Chapter 443,
   F.S., Unemployment Compensation, by the insurer
   taking the credit, a service representative as
   defined in s. 626.081, F.S., a supervising or
   managing general agent as defined in s. 626.091,
   F.S., and an adjuster or claims investigator as
   defined in s. 626.101, F.S.
3. Salary credit shall be allowed only to the extent
   that:
   a. The employees are not disqualified under s.
   624.509(5), F.S.;
   b. The employees are located or based in Florida; and
   c. The insurer claiming the credit is the employer,
   as defined in s. 443.036(17), F.S., of the claimed
   employees, and said insurer satisfies the Chapter
   38B-2, F.A.C., filing requirements.
4. Employees do not include independent contractors
   or any persons whose duties require them to have a
   valid insurance license issued under the Florida
   Insurance Code.
5. The wages paid to an individual who is employed
   directly by an employment agency, such as a temporary
   agency or a leasing company, are not included.

6. Net tax is the tax imposed under s. 624.509(1),
F.S., after deductions for the corporate income tax
imposed under Chapter 220, F.S., the emergency excise
tax imposed under Chapter 221, F.S., and for gross
premium receipts tax payable for firefighter's
pension trust funds under s. 175.101, F.S., and
police officers retirement funds under s. 185.08,
F.S.
(4) The maximum allowable credit for corporate income
tax, emergency excise tax and salaries cannot exceed
sixty-five percent of the tax due under s.
624.509(1), F.S., after deducting the taxes paid
under ss. 175.101, F.S., and 185.08, F.S., and
assessments pursuant to s. 440.51, F.S.
(5) Any insurer paying assessments made under s.
440.51, F.S., shall be allowed to take such amounts
as a deduction against the amount of any other tax
levied by the state upon the premiums, assessments,
or deposits for workers' compensation insurance on
contracts or policies of said insurance carrier,
self-insurer, or commercial self-insurance fund.
(6) Credits and deductions against the tax imposed by
ss. 624.509 and 624.510, F.S., shall be taken in the
following order:
(a) Deductions for assessments under s. 440.51, F.S.
(b) Credits for taxes paid under ss. 175.101 and
185.08, F.S.
(c) Credits for corporate income taxes paid under
Chapter 220, F.S.
(d) Credits for the emergency excise tax paid under
Chapter 221, F.S.
(e) Salary tax credit.
(f) All other available credits and deductions.
(g) A refund will not be created by credits.
... (Emphasis Supplied)
Section 443.036(44), F.S., states:
"Wages" means remuneration subject to this chapter
under s. 443.1217.
Section 443.1217(1), F.S., states in part:

The wages subject to this chapter include all
remuneration for employment, including commissions,
bonuses, back pay awards, and the cash value of all
remuneration paid in any medium other than cash....
(Emphasis Supplied)
Section 121.021(47), F.S., states:
"Bonus" means a payment made in addition to an
employee s regular or overtime salary. A bonus is
usually nonrecurring, does not increase the
employee's base rate of pay, and includes no
commitment for payment in a subsequent year....
(Emphasis Supplied)
Section 196.195(2)(a), F.S., states:
The reasonableness of any advances or payment
directly or indirectly by way of salary, fee, loan,
gift, bonus, gratuity, drawing account, commission,
or otherwise.... (Emphasis Supplied)
Section 196.2001(2)(b)1., F.S., states:
Any advances or payments directly or indirectly by
way of salary, fee, loan, gift, bonus, gratuity,
drawing account, commission, or otherwise....
(Emphasis Supplied)
Section 222.11(1)(a), F.S., states:
"Earnings" includes compensation paid or payable, in
money of a sum certain, for personal services or
labor whether denominated as wages, salary,
commission, or bonus. (Emphasis Supplied)
Section 288.905(6), F.S., states:
Any employee leased by Enterprise Florida, Inc., from
the state, or any employee who derives his or her
salary from funds appropriated by the Legislature,
may not receive a pay raise or bonus in excess of a
pay raise or bonus that is received by similarly
situated state employees.... (Emphasis Supplied)
Section 1012.72(2)(c), F.S., states:
An annual bonus equal to 10 percent of the prior
fiscal year's statewide average salary for classroom
teachers.... (Emphasis Supplied)
Rule 12-11.013, F.A.C., states:

Pursuant to the provisions of ss. 213.015(1) and
213.2201, F.S., the Department is authorized to issue
informal written technical statements called Tax
Information Publications (TIPs).
(1) Tax Information Publications are intended to:
(a) Provide guidance to taxpayers, tax practitioners,
and the public;
(b) Promote the uniform application of the tax laws;
(c) Inform taxpayers about the Department's response
to changes in:

1. United States or Florida tax laws; or,
2. Court or Division of Administrative Hearings
   decisions that interpret tax laws;
   (d) Explain to taxpayers their rights and
   responsibilities under the tax laws; and,
   (e) Assist taxpayers in complying with the tax laws.
   (2)(a) TIPs cannot supersede, alter, or otherwise
   change any provision of Florida law, Department rule,
   or any other source of law. They are not binding on
   the Department or on taxpayers, except as provided in
   Rule Chapter 12-13, F.A.C.
   (b) A TIP is not a rule under the provisions of
   Chapter 120, F.S.
   (3)(a) If there is an inconsistency between a TIP and
   a statute, rule, or court decision, the statute,
   rule, or court decision controls.
   (b) Any person relying on a TIP is required to
   consider the effects of later statute or rule
   changes, or court decisions, that render the TIP
   inapplicable. A taxpayer who relies on the
   provision(s) contained in an inapplicable TIP cannot
   subsequently allege that he or she received
   inaccurate guidance from the Department. (Emphasis
   Supplied)
   DISCUSSION
   Although "salary" and "bonuses" may be part of the overall
   compensation of the Taxpayer's employees, the two terms are
   separate and distinct. Salary is generally a set amount
   that is paid to an employee on a weekly, biweekly, monthly,
   or semimonthly basis. A bonus is a payment over and above

salary. Bonuses are often based upon a percentage of an
employee's salary and are generally a reward for
exceptional service by the employee and/or the company.
These common distinctions between "salary" and "bonuses"
are recognized and detailed in the Taxpayer's management
bonus plan and in the Florida Statutes. See Taxpayer's
Management Bonus Plan (effective as of January 1, 2000) and
ss. 443.1217(1), 121.021(47), 196.195(2)(a),
196.2001(2)(b)1., 222.11(1)(a), 288.905(6), and
1012.72(2)(c), F.S. Based on the above discussion, the
bonuses that the Taxpayer paid to its Florida employees are
not salary and are separate and distinct from salary.
Section 624.509, F.S., and Rule 12B-8.001, F.A.C., both use
the term "salary" when describing the payments, of an
insurer, to its Florida employees, that are required to be
used in the computation of the salary tax credit. The only
exception to the use of the term "salary" is the use of the
term "wages" in Rule 12B-8.001(3)(b)5., which excludes
payments to an individual who is employed directly by an
employment agency, such as a temporary agency or a leasing
company. The statute and rule are very specific and only
allow the salary tax credit for "salary" paid to Florida
employees.
Tax credits, exemptions, and deductions are a matter of
legislative grace and are not matters of right or equity.
Mostowy v. U.S., 966 F.2d 668, 674 (Fed Cir.1992); New
Colonial Ice Co. v. Helvering, 292 US 435, 440 (1935);
Arkansas Writers' Project, Inc. v. Ragland, 481 US 221, 233
(1987) (Scalia dissent); Commissioner v. Sullivan, 356 US
27(1958). The burden of clearly showing the right to a
credit is on the taxpayer. Indopco v. Commissioner, 503 US
79 (1992); Interstate Transit Lines v. Commissioner, 319 US
590 (1943); Deputy v. DuPont, 308 US 488 (1940); New
Colonial Ice Co. v. Helvering, 292 US 435 (1935). Tax
credits are strictly construed against the taxpayer and are
allowed only "as there is clear provision therefor.... A
taxpayer seeking a deduction must be able to point to an
applicable statute and show he comes within its terms." New
Colonial Ice Co. v. Helvering, 292 US 435, 440 (1935);
Indopco, Inc. v. Commissioner, 503 US 79, 83 (1992); Deputy
v. DuPont, 308 US 488,493 (1940); Straughn v. Camp, 293
So.2d 689 (Fla. 1974). Statutes allowing credits and
refunds are in derogation of the common law, and are
strictly construed. Department of Revenue v. Bank of
America, 752 So.2d 637 (Fla. 1st DCA 2000).
A review of the Legislative history surrounding the use of
the term "salary" in s. 624.509, F.S., provides additional
evidence that the Legislature was aware of its choice of
words. A proposed amendment contained in the archive file
indicates that there was an effort to use the term "wages,"
as defined in the unemployment statutes, instead of the
term "salary." However, this language was never adopted by
the Legislature.

The Legislature was aware of the common definition of
"salary" and of the definition of "wages" in the Florida
Statutes, and it chose to use the term "salary." The
Legislature was also aware that the term "salary" was
significantly more restrictive than the term "wages," when
it chose the wording for s. 624.509, F.S.
The power to grant tax credits resides with the
Legislature, and it is the will of the Legislature that
controls the application of the provisions for tax credits.
Biddle v. Commissioner, 302 US 573 (1938). Under
fundamental principles of separation of powers, courts
cannot judicially alter the wording of statutes where the
Legislature has clearly not done so. Department of Revenue
v. Florida Municipal Power, 789 So.2d 320 (Fla. 2001)
("Even where a court is convinced that the Legislature
really meant and intended something not expressed in the
phraseology of the act, it will not deem itself authorized
to depart from the plain meaning of the language which is
free from ambiguity.") In Department of Revenue v. Pirtle,
690 So.2d 709 (Fla. 4th DCA 1997), the court noted:
"Extrinsic evidence should not be consulted to clarify or
construe a tax statute couched in clear and unambiguous
language; however, where doubtful or ambiguous language
appears in a statute allowing for an exemption from
taxation, the statute should be strictly construed against
the taxpayer." Where taxpayers do not meet the literal
requirements for a tax credit provided in the statute, the
tax credit should be denied. Hokanson v. Commissioner, 730
F.2d 1245 (9th Cir. 1984). An agency's interpretation of a
statute, which it is charged with enforcing, is entitled to
great deference and will not be overturned unless it is
clearly erroneous or unauthorized. Department of Revenue v.
First Union National Bank, 513 So.2d 114 (Fla. 1987);
Donato v. American Tel. & Tel. Co., 767 So.2d 1146, 1153
(Fla. 2000).
The Taxpayer has the burden of proving that bonuses should
be included in the computation of the salary tax credit
provided in s. 624.509, F.S. Specifically, the Taxpayer
must show a clear provision that the term "salary" includes
bonuses. New Colonial Ice Co. v. Helvering, 292 US 435, 440
(1935); Indopco, Inc. v. Commissioner, 503 US 79, 83
(1992); Deputy v. DuPont, 308 US 488,493 (1940); Straughn
v. Camp, 293 So.2d 689 (Fla. 1974). Statutes allowing
credits and refunds are in derogation of the common law,
and are strictly construed. Department of Revenue v. Bank
of America, 752 So.2d 637 (Fla. 1st DCA 2000).
In Bank of America v. Department of Revenue, 752 So.2d 637
(Fla. 1st DCA 2000), the Court noted that the Florida
Legislature was presumptively aware that corporations
holding a right to a tax refund often transferred a
security interest to third parties. The 1st DCA stated:
"Despite the common knowledge concerning such transactions,

the legislature has not enacted a provision authorizing a
refund of the uncollected portion of the prepaid sales tax
to the dealer's assignee." The 1st District Court of Appeal
upheld the Department's position that a refund or credit is
personal to the particular taxpayer and cannot be
transferred or assigned to a third party absent specific
statutory authority. And, by extension, it can be said that
the Florida Legislature is presumptively aware that mergers
occur between corporations, but it has not enacted a
provision authorizing the acquisition of premium tax
credits by the acquiring corporation.
The Taxpayer suggested that the exclusion of commissions
from the salary tax credit indicates that commissions were
considered salary. However, it is quite logical that the
Legislature chose to emphasize the fact that commissions
are not salary because of the prevalence of paying
insurance agents on a commission basis. The Legislature
clearly did not intend to provide insurers this credit for
having insurance sales agents in Florida. The intent was to
replace the old home office and regional home office credit
and to encourage insurers to locate home offices and
regional home offices in Florida.
The Taxpayer states that it relied on Taxpayer Information
Publication (TIP) 95B8-19, issued on July 24, 1995, which
uses the term "wages" instead of the term "salary," when
describing the criteria for accepting the salary tax
credit. Although the TIP uses the term "wages" instead of
"salary," the wording and intent of section 624.509, F.S.,
controls. The TIP is not authoritative, and neither the
Taxpayer nor the Department can be bound by a TIP. See Rule
12-11.013, F.A.C.
CONCLUSION
Based on the discussion above and a plain reading of s.
624.509, F.S., "A's" bonus payments to its Florida
employees are not salary and are not included in the
computation of the salary tax credit.
This response constitutes a Technical Assistance Advisement
under s. 213.22, F.S., which is binding on the Department
only under the facts and circumstances described in the
request for this advice as specified in ?213.22, F.S. Our
response is based on those facts and the specific situation
summarized above. You are advised that subsequent statutory
or administrative rule changes or judicial interpretations
of the statutes or rules upon which this advice is based
may subject similar future transactions to a different
treatment than expressed in this response.
You are further advised that this response, your request
and related backup documents are public records under
Chapter 119, F.S., and are subject to disclosure to the

public under the conditions of s. 213.22, F.S. Confidential
information must be deleted before public disclosure. In an
effort to protect confidentiality, we request you provide
the undersigned with an edited copy of your request for
Technical Assistance Advisement, the backup material and
this response, deleting names, addresses and any other
details which might lead to identification of the taxpayer.
Your response should be received by the Department within
15 days of the date of this letter.
Sincerely,
Robert DuCasse
Technical Assistance and Dispute Resolution
RCD/
Control No.: 59626