In disputed tax cases in South Carolina, the South Carolina Department of Revenue (SCDOR, DOR, or Department) will often argue that our courts should defer to SCDOR’s own interpretation of the tax laws at issue in the case. Whether SCDOR’s administrative views are entitled to any weight and, if so, to what extent, are for our courts to decide. In the recent decision of Synovus Bank v. South Carolina Department of Revenue, Docket No. 17-ALJ-17-0418-CC, the South Carolina Administrative Law Court (SCALC or ALC) identified the standard under which SCDOR’s administrative ...
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