The Indiana Department of Revenue denied an out-of-state corporate taxpayer all research and development credits it claimed on its Indiana adjusted gross income tax returns. The taxpayer did not provide the necessary documentation to support the claimed amount of credits and therefore could not substantiate the numbers used to calculate the credits. Additional time was allowed for the submission of supporting documentation, but the taxpayer explained it did not have any such documentation. The Department noted in its decision that the burden of proving wrong a proposed assessment falls on the person against whom the proposed assessment is made, per Indiana Code Section 6-8.1-5-1(c).
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