Tax Commissioner Opinions
An "Opinion of the Tax Commissioner" means an opinion issued under R.C. 5703.53 with respect to prospective tax liability for certain taxes administered by the Commissioner. It does not include ordinary correspondence of the Commissioner or a Final Determination of the Commissioner arising from a request for administrative review of an assessment, refund claim, or an application for a pollution control or other certificate.
If a taxpayer requests in writing an Opinion from the Tax Commissioner as to whether or how certain property, income, sources of income, or activities or transactions will be taxed, the Commissioner may issue a written "Opinion of the Tax Commissioner" that shall bind the Commissioner in accordance with R.C. 5703.53.
The proper way to request an Opinion of the Tax Commissioner is to send a writing that comports with OAC 5703-1-12 to:
Tax Commissioner, Sarah O'Leary
Ohio Department of Taxation
30 East Broad Street
Columbus, OH 43215
Table of Contents
Tax Type | Subject Matter | Opinion (Year - Number) |
Commercial Activity | Agent | 08-0012 |
Agent | 08-0011 | |
Agent | 08-0007 | |
Agent | 08-0001 | |
Common Owner | 06-0005 | |
Consolidated Election | 06-0003 | |
Elected Consolidated Group | 05-0007 | |
Foreign Trade Zone | 05-0010 | |
Natural Gas Marketer | 09-0005 | |
Nonprofit Organization | 09-0002 | |
Nonprofit Organization | 08-0010 | |
Nonprofit Organization | 07-0002 | |
Corporate Franchise | Appreciation After Merger | 08-0009 |
Original Cost | 94-0002 | |
Statute of Limitations | 06-0001 | |
Corporate Franchise/ Personal Income |
OVCA Credits | 05-0011 |
Qualified Settlement Fund | 08-0003 | |
Qualified Settlement Fund | 99-0004 | |
Qualified Settlement Fund | 97-0001 | |
Employer Withholding |
School Districts | 06-0011 |
Personal Property | Foreign Trade Zone | 01-0005 |
Foreign Trade Zone | 93-0017 | |
Foreign Trade Zone | 90-0006 | |
Motor Vehicles | 91-0014 | |
Real or Personal | 07-0001 | |
Sale or Lease | 91-0024 | |
Sales Tax | Advertising Material | 94-0004 |
Affiliated Group | 93-0012 | |
Affiliated Group | 93-0019 | |
Automatic Data Processing | 92-0009 | |
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Billing and Collection Services
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Business Fixture
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Cable Television System
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Capitalized
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|
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Charities
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Cloud-based Applications | 14-0001 | |
Commercial Kitchen Equipment | 05-0009 | |
Construction Contracts | 20-0001 | |
Consumer | 91-0008 | |
Defibrillator | 05-0003 | |
Electronic Exemption Certificates | 06-0002 | |
Electronic Information | 05-0005 | |
Electronic Information Services | 20-0002 | |
Employment Placement | 93-0001 | |
Employment Placement | 93-0013 | |
Floor-Cleaning Equipment | 05-0004 | |
Food Premises | 93-0002 | |
Laundering Rental Articles | 93-0014 | |
Medical Devices | 00-0006 | |
900 Service | 92-0008 | |
900 Service | 90-0008 | |
Nursing Home | 92-0002 | |
Nutritional Supplements | 00-0002 | |
Point of Sale Coupon Service | 07-0006 | |
Price | 90-0011 | |
Real or Personal | 93-0020 | |
Refinancing Lease | 91-0012 | |
Sales to Exempt Organizations | 05-0008 | |
Salvage Vehicles | 04-0003 | |
Scaffolding | 05-0002 | |
Services as Things Transformed | 93-0021 | |
Soft Drink/Food Stamps | 05-0006 | |
Software | 05-0001 | |
Software | 91-0016 | |
Supplying Compressed Air | 08-0002 | |
Total Order Coupons | 02-0004 | |
Water Treatment | 93-0026 | |
Sales/Personal Property | Sale or Lease | 92-0014 |
Sales/Use | Advertising | 91-0020 |
Agriculture | 93-0004 | |
Automatic Data Processing | 91-0006 | |
Billing and Collection Services | 06-0013 | |
Casual Sales/Customized Software | 07-0003 | |
Computer Services | 92-0015 | |
Defibrillation Units | 00-0010 | |
Electronic Reports | 92-0007 | |
Employee Benefit and Human Resource Services | 04-0002 | |
Fulfillment for Direct Marketer | 07-0005 | |
Maintenance Contracts | 90-0009 | |
Medical Records | 91-0017 | |
Motion Picture Films | 06-0012 | |
Popcorn Conditioning Bins | 00-0004 | |
Prescription Drugs | 01-0002 | |
Property Management | 92-0016 | |
Public Utility Service | 90-0014 | |
Public Utility Service | 90-0012 | |
Publications | 91-0013 | |
Rebilled Costs | 92-0003 | |
Resale | 90-0013 | |
Service Plans | 91-0009 | |
Service Plans | 91-0005 | |
Technology Consulting Services | 08-0006 | |
Vendor/Construction Contractor | 91-0001 | |
Vitamins/Advertising/Shipping | 02-0005 |