When is a Department of Revenue Assessment not really an Assessment?

– The Department of Revenue issues a Notice of Proposed Assessment after completing a tax audit in Florida
– The Notice of Proposed Assessment becomes a “final assessment” within 60 days if not challenged by the taxpayer
– Verizon took the position that the NOPA did not constitute an assessment for statute of limitation purposes until 60 days after its issuance
– The First District Court of Appeal ruled in favor of Verizon, stating that a NOPA does not constitute an assessment for statute of limitations purposes as it’s not a “final” assessment.

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