New Hampshire Code of Administrative Rules
Rev - Department of Revenue Administration
Chapter Rev 2900 - GENERAL PROVISIONS RELATING TO ADMINISTRATION, RETURNS AND TAXPAYER RECORDS
Part Rev 2910 - VOLUNTARY DISCLOSURE PROGRAM
Section Rev 2910.07 - Voluntary Disclosure Agreement
Current through Register No. 12, March 21, 2024
(a) If the department determines that a taxpayer meets all the requirements in RSA 21-J: 3, XXXII and Rev 2910.06, and subject to Rev 2910.05 to participate in the program, the department shall prepare a voluntary disclosure agreement to settle and compromise the taxes and interest due for the look-back period.
(b) The voluntary disclosure agreement shall include the following terms:
(c) To participate in the program, the taxpayer shall sign and return the voluntary disclosure agreement to the department within 30 days from the date the department sent the voluntary disclosure agreement to the taxpayer.
(d) The voluntary disclosure agreement shall not preclude the department from auditing or otherwise investigating the taxpayer's liability for the look-back period, or from assessing further taxes, interest and penalties shown to be due by such an audit or investigation.
(e) The taxpayer shall be precluded from pursuing all statutory remedies, including the right to appeal, with respect to the taxes and interest settled and compromised through the voluntary disclosure agreement, except in the case of a further assessment pursuant to (d) above, or a federal audit change.
(f) A taxpayer shall be disqualified from the program, and the voluntary disclosure agreement rendered null and void, if the department finds any of the following:
(g) If the voluntary disclosure agreement is rendered null and void, the department shall be allowed to use any information ascertained through the program to assess taxes, interest, and penalties against the taxpayer not only for the look-back period, but for all tax years.