This protest involved whether the Department could grant the Taxpayer’s untimely refund claims. The Taxpayer’s claim was based on overpayments of gross receipts tax as the result of amended returns in periods from 2017 to 2019, when the Taxpayer had learned that third-party market providers had already paid the gross receipts tax on the Taxpayer’s short-term rentals. The Department denied the refund claims because they were made beyond the statute of limitations. The Hearing Officer, determining that there was nothing in statute that would allow the Department to grant the claims, denied the protest.
