FICPA / DOR LIASON MEETING – DECEMBER 11, 2015
[If there are any misspelled names or incorrect titles provided herein, then please email HERE so corrections can be made immediately. Thank you!]
Kevin Herzberg, CPA of Grant Thornton made initial statements and everyone introduced themselves.
Marshall Stranburg, executive director of the FL DOR, welcomes everyone. He talked how much times have changed over the last 25 years. We have gone from worrying about catalog sales to internet sales. Cell phones allow communications literally everywhere. Some taxes have gone by the wayside like intangible person property tax. New taxes have surfaced like the CST. Sales tax holidays are a new concept. He talked about how much we need to work together to help build our state to the most business friendly state in the country. Marshall introduced several new people in the DOR from legislative director, Debbie Longman, to property tax directors.
As a post meeting note, Marshall Stranburg accepted the job Deputy Executive Director for the Multistate Tax Commission in Washington DC. He will be leaving the FL DOR effective April 1, 2016. Since first joining the Department in 1991, he has also served as Deputy General Counsel, Chief Assistant General Counsel for General Tax Administration, and Assistant General Counsel. His replacement has not been announced as of the time of this article, but many are speculating that Andrea Moreland, Deputy Executive Director, will be nominated for the position.
Joe Handy, CPA, provided a plaque to Barbara O'Donnell, CPA, for her contributions to the FICPA and helping our members work with the FL DOR for many years. Barbara has been a very active participant in the FICPA and has acted as liaison between the FICPA and the FL DOR. Congratulations Barbara!
LEGISLATIVE UPDATE: Debbie Longman and Justin Thames provided a legislative update. Debbie started off discussing the up and coming 2016 legislative session, which will start January 12th (early) and end March 11th. About 1,600 bills have been filed to date. The DOR looks at every single billed that is filed to see if it will affect the DOR. The DOR is now tracking 250 bills as any one of them might affect something the DOR does. Whether it would require additional employees or even a change in tax forms, the DOR does a great job of keeping ahead of these issues before the bills come close to becoming law. The DOR is not submitting any bills during 2016. High points of tax legislation that passed in 2015:
House bill 33-A was passed in special session. The CST rate was permanently reduced. Several sales tax exemptions were added or changed. Agricultural, irrigation for farms, college text books (one year exemption), school support organizations, gun club membership fees not taxed, enterprise zone legislation preserving some exemptions passed when the current laws are set to expire, sales tax holidays, brown field tax credit extended, R&D tax credits had changes (from "first come first serve" to a one week application period in which all applicants get prorated share of credits) and increased to $23 million from $9 million.
Governor Scott's tax proposals have come out, which calls for $1 billion reduction in taxes. The governor's proposal includes: reducing the sales tax on commercial rent by 1%, permanently eliminate income tax on retail business and manufacturing, permanently eliminate sales tax on machinery and equipment, extend college text book exemption one year, back to school/hurricane preparedness holiday. Proposed other suggestions – veterans' holiday and small business Saturday (from other sources). Governor presented the proposal himself, rather unusual, to the House. The senate majority leader has invited the Governor to do the same to the Senate. All of this would cost around $1 billion dollars in less revenue.
Justin Thames spoke next. The FICPA tracks a lot more than just tax bills, but there is a heavy focus on tax bills as well. He gave an update on several bills. Tax holidays. Back to school holidays is likely to pass again. The governor's college text book holiday has a lot of momentum because it has backing by strong players in the House. The Senate is not as enthusiastic about all the Governor's proposed changes. There is discourse in the idea of state employee pay raises versus bonuses based on merit (gov idea). Reduction of sales tax on rent from 6% to 5% is proposed by Gov, which hopes to be a step-by-step reduction to eventually eliminate sales tax on commercial rent permanently. Justin mentioned that the FICPA does not have a legislative package either.
Gary Peric, Esq., CPA, State Tax Foundation Founder, asked a question about the difference between the "Tribal-State Gaming Compact" (coming initially from Governor Scott) versus the normal bill process (coming initially from the legislature). Big picture, if the legislature accepts the Governor's proposed Compact, then it becomes law without having to go back to the Governor, which is considered to be a faster process.
RULE MAKING PROJECTS: Mark Zych (Director of Tax Assistance and Dispute Resolution, aka TADR). Big rule package just made it to the Legislature and is expected to be ratified in January and effective July 2016. Kim Bevis joined Mark in the presentation. Technical Assistance and Dispute Resolution (TADR) reviews all bills that affect tax. TADR's job is to provide the effects of the proposed legislation as written and whether it has administrative complications. Mark says that they don't want to create "I gotcha" rules. Kim discusses the new bills. 2014 legislation – looked at 7 new laws. Veterinary exemptions, electricity exemptions, electronic reporting rules (911 fees), scholarship funding, reduced rental car surcharge fee, clean up of registration penalty, delegation of authority to compromise rules update. 2014 – 7 administrative changes: Mobile application was created with rules applicable (valid form of exemption documentation), downloadable resale exemption certificate option for taxpayers, new turn in your neighbor for noncompliance rules to better allow rewards, disclosure procedures updated to allow email or fax provided records from the DOR vs snail mail.
2015 legislative changes: 16 TIPs published. The main things focused on with rule changes: two heavily focused on income tax side, e.g. R&D exemption and FL space exemption act required new rules, flight training exemptions for colleges and universities (motor fuel), changes to agriculture exemptions required rules (irrigation, stakes, equipment, etc). Joe Moffa, CPA and Attorney, asked if there was a new rule in the works for the Marine exemptions. Debbie said no, but discussion with industry was taking place. Cleaned up resale exemption certificate and other exemption certificate rules. Two witness requirement removed from closing agreements. Repeals a few forms: 9 forms repealed and cross references. 3 form changes for insurance forms. Several changes to income tax forms. Minor changes to sales tax forms. TADR has requested legislative change to make it easier for taxpayers to get consumer exemption certificates as well as auto renewals (hope to have it approved by March 2016). Returned merchandise is a big issue that had a recent rule workshop in which numerous industry gave feedback.
Glenn Bedonie, CPA and former Director of TADR, brought up the topic for discussion regarding the requirement for purchases made with a consumer exemption certificate to be paid the by the organization. If the employee pays for the good or service personally to be reimbursed by the organization, then the consumer exemption certificate may not be used to buy that good or service tax free. While it has always been part of the statutory requirement, the documentation required to prove the exemption upon sales and use tax audit had not been strictly enforced. Somewhat recently, the DOR began requiring hotels to prove that the source of the payment came from the exempt organization. It took several years and thousands of dollars in taxes imposed on hotels before the industry learned to keep the proof of the source of payment information. In the last year or so, the DOR started requiring all vendors to provide proof that the payment came from the exempt organization when a consumer exemption certificate is used. The problem here is that the vast majority of businesses are not set up to collect this additional information. Vendors don't keep copies of checks used, credit cards must be in company names, and cash transactions result in no proof of the payer. Furthermore, as raised by James Sutton, CPA and Attorney, the overwhelming majority of credits cards with company names on them are really the personal credit card of employee because credit card companies rarely issue credit cards to a legal entity. Mark Zych pointed out that they are merely trying to follow the statute as best they can. No solution was suggested to fix the issue. Perhaps the best first step is for the FL DOR to add language to the exemption certificate itself that reflects proof of payment from the exempt organization is required for the exemption certificate to be validly used.
GTA OVERVIEW AND UPDATES: Maria Johnson, General Tax Administration Program Director, talked about new funds to hire new auditors and a better path for advancement. Rich Unen, Director of Audit, discussed the successful hiring that had taken place for auditors over the past year, including recruiting at many colleges. James Sutton asked if there were any specific industries that the Department planned to target over the next year. Maria responded that there were not any new industries but continued focus on convenience stores and car dealers was to be expected as well as a significant increase in the number of reemployment tax audits – and that we could expect combined SUT & RT audits in the near future.
There was also mention of work being done to reliably pull information from 3rd party sources on transient rentals, such as www.vbro.com. Property management companies that collect rent are required to be registered (and are liable for the sales tax), but many do not update the information with the DOR regarding what properties they are managing. Joe Handy mentioned that the voluntary collection of sales tax by AirBnB.com has to be a win for the state.
Kevin Herzberg asked if there was anything in the works regarding the new IRS regulations minimizing audit documentation for fixed asset purchases under certain dollar amounts. Kevin pointed out that many taxpayers would not have the documents necessary for sales tax audits after changing practices for IRS paperwork purposes. Bill Jones, CPA, raised the question about increases in the exemption for TPP returns. Rich Unen responded that this is more of a property appraiser issue at the county level. It is worth noting that the DOR has been initiating letter audits based on increases in assets reported on companies TPP returns – even if the increase is merely an estimate by the county.
Maria Johnson addressed the room saying that proper documentation is always a problem on audits and asked the room for suggestions on how to improve this. James Sutton suggested that educating new taxpayers would be the best approach, to significant laughter from the DOR personnel in the room. James pointed out how easy it is for a business owner to get a license to do something that requires tax collection but the DOR has failed to provide interactive training to business owners since 2008 as required by Sec. 213.015, F.S. For example, a used car dealer has very tricky requirements for sales tax collection and paperwork, but no training is required or even offered to get a used car dealer license. Instead of training these car dealers, the DOR initiates a statewide audit campaign on the industry. Maria recognized that James had raised this issue for several years now and said this was a perfect segway into a new program the DOR is starting in cooperation with a not for profit organization and turned the floor over to Carmen Rosamonda, Director of Collections.
Carmen Rosamonda, Director of Collections, discussed a new and innovative program in which the DOR will work with a 3rd party business success program to educate new business startups on how to start and run a successful business. The DOR will provide facilities for the training to new businesses and will also provide personnel to provide training on how to collect and remit Florida taxes. The training sessions will be recorded and it is foreseen that the sessions will be made available online. This is a great step forward for taxpayers and we wish this program all the best of luck!
Given the recent Verizon Business Purchasing case (a huge loss for the DOR), Rich Unen discussed the focus for audits to be finished soon enough to issue the Notice of Proposed Assessment 60 days before the statute of limitations expires. Rich mentioned that the DOR did not want the taxpayer to feel rushed and that extension can be granted if the taxpayer needs more time.
Joe Moffa, CPA and Attorney, raised the issue of auditors going around the Power of Attorney to contact the taxpayer directly if the auditor did not like the answers they were getting. Joe also raised the issue that the auditors were pushing to start the audits before the 60 day mark on a very regular basis. Joe suggested that this is a training issue that needs to be addressed with both in-state and out-of-state auditors. Rich Unen said this should not be happening and that he agrees the issue should be addressed better in training. Barbara O'Donnell, CPA, asked if Joe was suggesting the DOR not contact the taxpayer at all in the first 60 day period. Joe responded that the auditors can reach out but not be pushy about it. If the taxpayer or POA says they want to take the 60 day period to start the audit, then the auditor should respect the request.
James Sutton, CPA and Attorney, raised collection issues while Carmen Rosamonda was present. James raised the fact that the DOR's ability to impose 200% of tax penalties on business owners (and other responsible parties) completely ignoring corporate shell liability protections is one of the greatest and most threatening powers the DOR has been given by the legislature. James mentioned that we have been seeing final assessments combined with immediate 200% personal liability penalties. James mentioned that personal liability penalties are being imposed after audits that had 100% of the penalties on audit removed, indicating someone in the DOR had already determined that no willful intent to defraud was present (a requirement to impose the 200% of tax penalty). James suggested that the collectors are over using the 200% penalties are a mere collection threat without enough oversite. James also raised the issue of back levies being imposed before warrants had been issued more than the required time frame. Carmen detailed the collections process step-by-step and said that he was sure no levies were issued before warrants had been issued nor were the 200% personal penalties being imposed before warrants had been issued on the business. James raised the situation when the taxpayer files a petition for further review under sec. 213.21 (after the right of appeal has passed) and that the 200% personal liability notices are hitting the taxpayer with no notice that the petition for further review had been denied. Carmen stated that he was sure everything in his department was being done right and to call him if we see otherwise.
Just in case someone from the DOR collections department reads these notes, there is another issue that should be addressed. Some collectors are threatening to have a sheriff come to the taxpayer's business and arrest them or close the business the next day if they do not bring a check to the DOR before the close of the business day. No DOR collector in the state of Florida has the authority to have a taxpayer arrested or shut down the business unilaterally. There is a "revocation process" that can close the business down, but it takes months and the taxpayer has significate due process rights before the business can be closed down. Furthermore, while the DOR does have an investigation division responsible for detecting and deterring criminal activities regarding Florida taxes, no investigator working for the Department of Revenue has the authority to arrest a taxpayer. Arrests warrants must be reviewed by the state attorney's office and approved by a judge before a sheriff may arrest anyone for sales tax related crimes. Under no stretch of the imagination does a collection agent have the authority to send a sheriff out to have the taxpayer arrested. It would be good if this information would be passed along to the all collectors.
Joe Moffa, CPA and Attorney, brought up the topic of Stipulated Payment Agreements and Compliance Agreements in which taxpayers are being forced into with payment plans where the taxpayer knows, from day one, they can't afford the monthly payments. Quite often at the time of the negotiation, the DOR collection agent has the business bank account frozen, leaving the business owner no choice but to sign the agreement or close the business. This happens even if some of the liabilities are erroneous or would have been removed if challenged properly. The agreements are so one-sided and require the taxpayer to give up all challenge rights while leaving the DOR all rights to re-audit or change the assessment. Joe suggested that there has to be a way for taxpayers to enter agreements to start paying, have their bank accounts unfrozen, but still be able to address the underlying assessment or at least get more reasonable payments for longer periods of time. This is especially egregious when there is an unrepresented taxpayer. Mark Zych said that if the DOR and Taxpayer agree, both parties can agree to review the underlying assessment. Carmen Rosamonda said that the DOR expects the taxpayer to work out everything during the audit and collections process. Tammy Miller, with TADR, said that she didn't think TADR had the legal ability to alter just penalties (which is a questionable position under Sec. 213.21).
James Sutton raised a tangential issue that after stipulated payment agreements have been entered into, the DOR's collection analytics (automatic collection process) is automatically canceling payment agreements because of minor issues and often because of the DOR's failure to process payments timely. Maria Johnson said that the DOR is working to improve collection analytics, which is a relatively new system.
TAXPAYER RIGHTS ADVOCATE: Marshall Stranburg took over this presentation as the original speaker was out for a family emergency. The Taxpayer Rights Advocate has been conducting independent surveys of audits to the tune of 30 to 35 per month. This is in addition to the survey given to taxpayers at the end of an audit. The thought is that taxpayer's might feel more comfortable responding to what may be perceived as a more independent department. The response rate has been around 20% for responses to surveys provided to taxpayers with the audit paperwork. The hope is that the rate will be higher coming from the taxpayer advocate.
James Sutton asked if there was any written record of complaints made through the Taxpayer Advocate in the past to compare the survey results. Marshall responded that the Taxpayer Advocate meets with Marshall and Maria every month to discuss what issues are arising. Marshall delicately dodged the real question, which was designed to highlight the fact that the Taxpayer Advocates' Office has been instructed to not keep written records of complaints made to the Taxpayer Advocate presumably so the complaints would not be public record. There has been a growing concern in the state tax community that the Taxpayer Advocate's Office is not able to operate independently enough when the department reports directly to the agency that it is supposed to be overseeing. You may hear more on this issue over the next year.
Joe Handy suggested that the surveys should be sent to POA's as well as taxpayers. The DOR responded that they were considering sending the survey to POA's and whether to make the survey available online to increase the response rate. Maria Johnson said that over 90% of the responses so far have been positive. Marshall Stranburg also suggested that the POA can always call the Taxpayer Advocate to communicate areas that need improvement.
Glenn Bedonie suggested that auditors and collectors need sensitivity training especially for small business owners that are terrified of what the DOR might do to them on audit.
LITIGATION UPDATE: George (Tony) Hamm and Isabela Nogues (both with General Counsel's office) addressed litigation issues over the last year. The first case raised for discussion was Verizon Business Purchasing, which held that a Notice of Proposed Assessment (NOPA) was not a final assessment until it had been issued for 60 days. The DOR's position on this case is that if the audit period had been extended by a DR-872, then a late issued NOPA would result in the entire assessment being withdrawn. If no DR-872 was issued, then the DOR will withdraw only the number of months directly affected by the delay in the NOPA becoming final. In other words, if the NOPA is issued two months late, then the oldest two months of the audit period would be ignored in the audit. Peter Stephens (formerly the DOR's Director of Audit) asked several clarifying questions. Joe Moffa mentioned that this was probably the most significant case involving the DOR in many years. Marshall Stranburg stood up to address the room with his concerns about the Verizon case. Marshall said he thought this was not a favorable case because he said it affected refund rights of taxpayers. From Marshall's perspective, if there are any refunds in the audit, then the taxpayer would need to file a protective claim for refund at the time the NOPA is issued. Marshall felt that the refund rights were lost because of the verbiage of the Verizon decision. Glenn Bedonie asked for clarification when taxpayer's should ask for a refund. Marshall responded that he thought it would be malpractice if a POA did not file a Form DR-26s when you sign a DR-872. Glenn brought up the issue that you could be considered to be committing fraud if you file a refund claim and you are not sure if there should be a refund. Good point. Joe Moffa raised the issue that if the NOPA was issued late and it contains an audit period that is not valid (because at least part of the period is outside of the SOL), then is the final assessment invalid on its face (defective)? Glenn asked for clarification again about the timing of filing a refund claim. Marshall said that he can't give legal advice.
Joe Moffa then asked the total amount of assessment withdrawn due to the Verizon case. Marshall Stranburg and Mark Zych talked back and forth across the room, deciding this is something they could answer. Mark said that it had been about $135 million dollars to date. Tony Hamm quickly clarified that several of the much larger cases involved more than just the Verizon issue, which would have resulted in significant reductions in the assessment regardless of Verizon.
Isabela Nogues then discussed the American Business USA case, which is currently before the FL Supreme Court. Florida (along with more than half the states) have special sourcing rules for florists. If a Florist sells flowers across state lines, then the state in which the original order is taken is where the sales tax is due. This is the case even if the person ordering the flowers is not in Florida and the Flowers are fulfilled by a florist completely outside Florida. This case involved an online marketer of flowers, but the company does not hold any inventory of Flowers. The company, based out of Winter Haven Florida, took flower orders for delivery all over the world, but primarily in Central America. The company charged sales tax for flowers delivered in Florida, but not on orders fulfilled outside Florida. The DOR conducted an audit and assessed over $120,000 in sales tax. The taxpayer lost at trial, but the taxpayer won on appeal in which the court held the statute unconstitutional (violated the dormant commerce clause). The DOR appealed to the Florida Supreme Court and oral arguments were a couple of weeks prior to the liaison meeting. It is also worth noting that James Sutton, co-author of this article, submitted an amicus curiae brief on behalf of the American Association of Attorney – Certified Public Accountants, PA on behalf of the taxpayer. We are waiting for the results.
Next Isabela raised two cases, American Heritage Window Fashions as well as Foster Windows and Doors. Both cases involving a situation in which a taxpayer was audited, no protest or court challenge was filed to challenge the assessment, the DOR began collection efforts, then the taxpayer paid part of the assessment and filed a refund claim. The question is whether the taxpayer has a right to file a refund claim under the circumstances. Both cases were denied at the trial level and both were appealed. One appellate decision came down the day before the liaison meeting against the taxpayer. The other is still pending. Both of these cases are being handled by Joe Moffa. It is worth to note that taxpayers have a right to file for a refund claim under IRS rules in this situation and it has always been believed that taxpayer's in Florida had the same right. Only recently has the DOR decided to start challenging these cases. Joe suggested that everyone in the room file timely challenges for their clients so they would not have to go through these types of actions.
Next case mentioned was DirecTV and Dish, a case that has been ongoing close to a decade. This case involves whether it is unconstitutional to charge higher Communication Services Tax rates on out of state satellite companies compared to in-state cable companies, who are essentially direct competitors. The difference between the tax rates originates because there is an additional tax imposed on cable companies that is not imposed on satellite companies, but it is a tax completely separate from the CST imposed on customers of these companies. In at least one author's opinion, this is likely going to be held unconstitutional.
Isabela then very briefly mentioned AT&T case and a case involving HCA. The AT&T case involves taxes on internet access and the HCA case involves corporate income taxes (facts intensive). Finally, Isabela mentioned two insurance premium tax cases there were very early in the litigation process and the DOR could not discuss them at this point in time.
Heather Miller and Ann Rix then discussed several TAA's that had been issued over the last year.
- TAA 14A029 taxability of wheelchairs and other mobility products. Items are specifically exempt. Some are not specifically exempt but with prescription would be- ex, medical bath bench.
- TAA 15A001- manufacturer of orthopedic implants and specialized tools.
- TAA 15A009- kitchen hood cleaning
- TAA 15A011- taxability of various sales of equestrian supplies.
- TAA 15A004- interior designs fees subject to tax?
- TAA 14A031- sale of electricity by the taxpayer to a city subject to gross receipts tax?
- TAA 15A006- taxpayer must collect communication services tax for discounted internet based admissions provided by another company? Sales tax would be due from admissions provider and not the taxpayer that posted the admission on the internet. No communication service tax due
- TAA 15A-005- direct sales to correctional inmates. Envelope with postage on it.
- TAA 15A-012– unrefrigerated meals sold to inmates by a party that contracted with the state. Meals subject to sales tax? No because unrefrigerated and were required to be heated by the customer before being eaten. Not subject to tax.
Joe Handy asked for more detail regarding the unrefrigerated meals TAA. Joe asked about grocery chains and delis that sell a lot of unrefrigerated meals. Joe asked for more guidance in this area because the guidance did not address the common stance of the DOR whether the meal would be eaten on the premises. Did it matter who did the heating? Ann Rix suggested submitting another TAA to get answers to these questions. James Sutton raised a simple fact scenario regarding a cold burrito you might buy at a convenience store. The customer buys the cold burrito and may or may not heat it before actually buying the burrito. Ann responded that they addressed this in the TAA, specifically that because food was required to be heated and the heating was done by the customer, the item would not be taxable. Glenn Bedonie asked a clarifying question regarding frozen banquet meals not being taxable. Mark Zych chimed in saying to be cautious because sandwiches are always taxable and a burrito comes pretty close to being a sandwich. It is amazing how complicated sales tax can get in Florida, even when you have all the brightest sales tax minds in one room. How in the world are taxpayers supposed to figure this out?
Glenn Bedonie then raised the Papa Johns case in which the taxpayer is subject to a class action suit involving whether the taxpayer properly collected sales tax on delivery fees. James Sutton chimed in saying this case is only one of a slew of cases popping up around the country, which creates a whole new concern for taxpayers. Historically, when an area of tax law was "grey," taxpayer often collected and remitted the tax to be safe from audit. However, these new customer class action law suits make it more important than ever for a business to collect exactly and only what is legally due. This not only puts a higher burden on businesses, but it also creates more of an obligation on state tax departments as well as the legislature to be as clear and unambiguous as possible when drafting and interpreting sales tax laws. James warned that tax professionals should make sure their clients were away of these types of class action cases.
A tip was issued warning taxpayers that enterprise zones are set to expire on 12/31/15.
Bill Jones, CPA, raised the issue of many S-Corporations receiving corporate income tax return late filling notices. Mark Zych said to just send proof that the taxpayer is an S-Corp and the DOR should drop the issue.
Mark Zych raised the issue of the taxability of some goods/services being tied to NAICS codes. This can create problems and opportunities. James Sutton mentioned that it is extremely important to research what other NAICS codes might apply to your client. If your client more clearly falls into a non-taxable code, then no tax is due. James raised the issue of a company cleaning homes under construction, which seem to clearly fall under taxable non-residential cleaning services. However, there is a narrower NAICS code for construction cleaning that is not mentioned in the taxing statute, so not taxable.
Someone mentioned the $60k sales tax cap on boat repairs. The cap is per invoice, so the entire repair needs to be on one invoice. Otherwise, the cap is applied on each invoice. Using one contractor to oversee all repairs with once invoice can accomplish this, but the contractor will likely charge a nice fee. Mark also warned about docking fees being subject to sales tax.
Joe Moffa asked about emailing protests versus sending in hard copies. Tammy Miller said the protest email has been up for a year now and email was fine. Joe responded that were concerned about confirmation. Tammy responded that you get confirmation via email. Joe mentioned that he often files more than one protest in a day and the response is not taxpayer specific. Tammy would look into this issue.
The meeting ended about an hour early with many handshakes. The FICPA / DOR Liaison meeting has been around for decades and is worthwhile for anyone that practices in this area.
Co-Author: James Sutton is a Florida licensed CPA and Attorney and a shareholder in the law firm the Law Offices of Moffa, Sutton, & Donnini, P.A. Mr. Sutton's primary practice is Florida tax controversy, with a almost exclusive focus on Florida sales and use tax. Mr. Sutton worked for in the State and Local Tax department of one of the Big Five accounting firms for a number of years and has been an adjunct professor of law at Stetson University College of Law since 2002 teaching State and Local Tax, Accounting for Lawyers, and Federal Income Tax I. Mr. Sutton is a frequent speaker on Florida sales and use taxes for the FICPA, Lorman Education, and Florida Society of Accountants. Mr. Sutton is also co-author of CCH's Sales and Use Tax Treatise. You can read more about Mr. Sutton in his firm bio.
Co-Author: Jennifer Pemble, CPA, CFE is a Tax Supervisor with Warren Averett, LLC in Tampa, Florida and practices in the area of state and local tax. Prior to joining Warren Averett, Jennifer was a corporate income tax field auditor for the state of New York for almost 5 years. Jennifer has her bachelor's degree in accounting and an MBA in financial fraud examination, both from Saint Xavier University in Chicago, Illinois. You can reach Jennifer at 813-280-7820 or Jennifer.Pemble@WarrenAverett.com.
ADDITIONAL RESOURCES
2014 FICPA DOR LIAISON MEETING SUMMARY, published December 10, 2014, by James Sutton, CPA, Esq.
2013 FICPA DOR LIAISON MEETING SUMMARY, published November 27, 2013, by James Sutton, CPA, Esq.