U.S. Bancorp & Subsidiaries v. Department of Revenue

HENRY C. BREITHAUPT, Judge.

This matter is before the court on a Motion for Reconsideration filed by Defendant Department of Revenue (the department). Pursuant to TCR 80, the department requested the court to reconsider certain language in its earlier Opinion in this matter. Plaintiff (taxpayer) has taken no position on the request for reconsideration.

Having considered the department’s request, the court clarifies its earlier Opinion.

I. CLARIFICATION ON TIME OF NOTIFICATION BY TAXPAYER TO THE DEPARTMENT

In the initial Opinion the court stated, in part:

“The stipulations and other evidence show…