Reopening an Audit
(1)Policy. When an issue has been audited, a position taken, and the case closed, that issue may be reopened for audit if there is evidence of fraud, malfeasance, concealment, misrepresentation of material fact, omission of income, or collusion either by the tax payer or by the taxpayer and a representative of the department. If income or expenses are claimed on a return from an outside entity, those items of income or expenses may be adjusted if the entity is later audited and adjustments are made.
(2)Definitions. Audited. An issue is not considered to have been “audited” unless the department has examined the issue and verified supporting documentation. Requesting a copy of a federal schedule is not an audit.
Rule 150-305-0198 — Reopening an Audit,