Rheem Manufacturing Co. v. Alabama Department of Revenue

BRYAN, Judge.

Rheem Manufacturing Company (“the Taxpayer”) appeals the Montgomery Circuit Court’s judgment holding that the Administrative Law Division (“the Division”) of the Alabama Department of Revenue (“the Department”) did not have jurisdiction to grant the Taxpayer a refund of franchise taxes based on a ground that the Taxpayer had not asserted when its claims for refunds of franchise taxes were before the Department. We affirm.

The Taxpayer paid to the Department franchise taxes for the tax years 1994 through 1999. Subsequently, the Taxpayer timely filed with the Department claims for…