The Tax Commissioner shall abate any portion of any tax, interest, and penalty attributable to erroneous advice furnished to the taxpayer in writing by an employee of the Department acting in his official capacity if:\n1. The written advice was reasonably relied upon by the taxpayer and was in response to a specific written request by the taxpayer;\n2. The portion of the penalty or tax did not result from a failure by the taxpayer to provide adequate or accurate information; and\n3. The facts of the case described in the written advice and the request therefor are the same, and the taxpayer's business or personal operations have not changed since the advice was rendered.\n1996, c. 634.
Virginia Legal Code