Tax Alerts
Tax Briefing(s)
Software engineer denied deductions for Executive MBA degree
Expenses for an MBA degree may or may not be deductible depending upon a taxpayer’s current employment situation. Take two close cases with opposite results:In Creigh, TC Summary Opinion 2017-26...
Expenses for an MBA degree may or may not be deductible depending upon a taxpayer’s current employment situation. Take two close cases with opposite results:In Creigh, TC Summary Opinion 2017-26...
President directs IRS to exercise discretion in enforcement of “Johnson amendment”
An Executive Order, issued on May 4, directs the IRS to exercise maximum discretion in its enforcement of the "Johnson amendment" concerning Code Sec. 501(c)(3) charitable/religious organizations. &nb...
An Executive Order, issued on May 4, directs the IRS to exercise maximum discretion in its enforcement of the "Johnson amendment" concerning Code Sec. 501(c)(3) charitable/religious organizations. &nb...
IRS updates FAQs on passport certification
In 2015, Congress added Code Sec. 7345 as part of the Fixing America’s Surface Transportation Act of 2015 (FAST Act). Upon receiving certification of seriously delinquent tax debt from...
In 2015, Congress added Code Sec. 7345 as part of the Fixing America’s Surface Transportation Act of 2015 (FAST Act). Upon receiving certification of seriously delinquent tax debt from...
No equitable relief from missing tax court deadline for innocent spouse review
The Third Circuit Court of Appeals has found that the Tax Court properly dismissed for lack of jurisdiction an individual’s petition for review of the IRS’s denial of innocent spouse relie...
The Third Circuit Court of Appeals has found that the Tax Court properly dismissed for lack of jurisdiction an individual’s petition for review of the IRS’s denial of innocent spouse relie...
Stock broker proves real estate professional status for rental losses
Winning real estate professional status –and the benefits gained from taking business deductions and losses from an “active” rather than “passive” business-- often depend...
Winning real estate professional status –and the benefits gained from taking business deductions and losses from an “active” rather than “passive” business-- often depend...
CBO reports on top tax incentives/expenditures
The Congressional Budget Office (CBO) issued a report in mid-March about current tax incentives. Tax expenditures, CBPO explained, reduce the amount of revenue that is collected for any given set of s...
The Congressional Budget Office (CBO) issued a report in mid-March about current tax incentives. Tax expenditures, CBPO explained, reduce the amount of revenue that is collected for any given set of s...
IRS updates 401(k) hardship distributions exam materials
The IRS Tax Exempt and Government Entities Division (TE/GE) has updated guidance used to determine whether a Code Sec. 401(k) plan hardship meets the safe-harbor standards set forth in applicable regu...
The IRS Tax Exempt and Government Entities Division (TE/GE) has updated guidance used to determine whether a Code Sec. 401(k) plan hardship meets the safe-harbor standards set forth in applicable regu...
Employee consent requirements for employer refund claims released
The IRS recently issued the employee consent requirements that an employer need to adhere to in order to support a claim for refund of overpaid taxes under the Federal Insurance Contributions Act (FIC...
The IRS recently issued the employee consent requirements that an employer need to adhere to in order to support a claim for refund of overpaid taxes under the Federal Insurance Contributions Act (FIC...
New Offers in Compromise policy starts April 27
The IRS informed taxpayers and tax professionals of its updated policy with regards to the Offer in Compromise (OIC) application process. OIC applications received on or after March 27, 2017, will now...
The IRS informed taxpayers and tax professionals of its updated policy with regards to the Offer in Compromise (OIC) application process. OIC applications received on or after March 27, 2017, will now...
Tax refund offsets may be used toward unpaid debts
A taxpayer who incurs an unpaid debt may notice a reduction in his or her federal tax refund. The Treasury Offset Program is allowed to use all or part of a taxpayer’s federal refund to settle u...
A taxpayer who incurs an unpaid debt may notice a reduction in his or her federal tax refund. The Treasury Offset Program is allowed to use all or part of a taxpayer’s federal refund to settle u...
Passport certifications will begin in early 2017, IRS posts on website
The IRS has informed taxpayers via its website that the agency will begin, in early 2017, to remit certifications to the U.S. State Department for individuals who are seriously delinquent in paying th...
The IRS has informed taxpayers via its website that the agency will begin, in early 2017, to remit certifications to the U.S. State Department for individuals who are seriously delinquent in paying th...
Tax returns lacking ACA coverage status will not be rejected
The IRS has announced that it will continue to process individual returns that do not report the taxpayer’s health coverage status under the Affordable Care Act (ACA). The IRS will accept return...
The IRS has announced that it will continue to process individual returns that do not report the taxpayer’s health coverage status under the Affordable Care Act (ACA). The IRS will accept return...
Dentist persuades Tax Court of material participation in real estate business
The Tax Court determined, in Zarrinnegar v. Commissioner, TC Memo. 2017-34, that a dentist by profession, was a real estate professional, and therefore could deduct rental real estate losses. As such,...
The Tax Court determined, in Zarrinnegar v. Commissioner, TC Memo. 2017-34, that a dentist by profession, was a real estate professional, and therefore could deduct rental real estate losses. As such,...
IRS confirms automatic six-month extension for C corporations
The IRS has confirmed that a new revision of the Instructions for Form 7004 correctly reflects that calendar year C corporations are eligible for an automatic six-month extension. Code Sec. 6081(a) pr...
The IRS has confirmed that a new revision of the Instructions for Form 7004 correctly reflects that calendar year C corporations are eligible for an automatic six-month extension. Code Sec. 6081(a) pr...
Future pension payouts not counted as asset in determining insolvency exclusion
The Tax Court, in Schieber v. Commissioner, TC Memo. 2017-32, found that the right to a continuing monthly payment state pension plan was not an asset in determining insolvency for purposes of exclusi...
The Tax Court, in Schieber v. Commissioner, TC Memo. 2017-32, found that the right to a continuing monthly payment state pension plan was not an asset in determining insolvency for purposes of exclusi...
AL - Updated chart shows local participation in 2017 “Back-to-School” tax holiday
The Alabama Department of Revenue has revised a chart that reflects the latest information concerning the counties and municipalities that have notified the department regarding their participation in...
The Alabama Department of Revenue has revised a chart that reflects the latest information concerning the counties and municipalities that have notified the department regarding their participation in...
AK - DOR discusses effects of potential Alaskan government shutdown
For purposes of taxes and the unclaimed property law it administers, the Alaska Department of Revenue (DOR) has issued a release detailing the effects of a possible government shutdown on July 1, 2017...
For purposes of taxes and the unclaimed property law it administers, the Alaska Department of Revenue (DOR) has issued a release detailing the effects of a possible government shutdown on July 1, 2017...
AZ - Deduction allowed for net capital gain and addition required for net capital loss from exchange of legal tender
For taxable years beginning after December 31, 2017, Arizona individual and corporate income tax deductions are allowed for any net capital gain included in Arizona gross income for the taxable year t...
For taxable years beginning after December 31, 2017, Arizona individual and corporate income tax deductions are allowed for any net capital gain included in Arizona gross income for the taxable year t...
AR - Taxpayer was domiciled in state and taxable as resident
A taxpayer was domiciled in Arkansas and was taxable as a resident of Arkansas for personal income tax purposes for 2014, because she failed prove that she changed her domicile to another state before...
A taxpayer was domiciled in Arkansas and was taxable as a resident of Arkansas for personal income tax purposes for 2014, because she failed prove that she changed her domicile to another state before...
CA - Tax rates in riverside county discussed
The California State Board of Equalization (BOE) reminds taxpayers that nine cities within Riverside County impose a sales and use tax rate of 8.75%: Cathedral City, Coachella, Hemet, Indio, La Quinta...
The California State Board of Equalization (BOE) reminds taxpayers that nine cities within Riverside County impose a sales and use tax rate of 8.75%: Cathedral City, Coachella, Hemet, Indio, La Quinta...
CO - Beneficial apportionment factors allowed for taxpayers investing in enterprise data centers
For corporate income tax purposes, Colorado Gov. John Hickenlooper has signed legislation allowing a taxpayer that makes a capital investment in an enterprise data center in Colorado to use a benefici...
For corporate income tax purposes, Colorado Gov. John Hickenlooper has signed legislation allowing a taxpayer that makes a capital investment in an enterprise data center in Colorado to use a benefici...
CT - Quarterly list of distributors issued
The Connecticut Department of Revenue Services has issued a quarterly list of persons who have become, or are no longer, licensed as distributors for Connecticut motor fuels tax purposes since the cur...
The Connecticut Department of Revenue Services has issued a quarterly list of persons who have become, or are no longer, licensed as distributors for Connecticut motor fuels tax purposes since the cur...
DE - Delaware adopts federal return due dates
Legislation has been enacted that adopts federal filing deadlines for Delaware corporation income tax, partnership, and W-2 and 1099 series information returns. The due date for C corporation returns ...
Legislation has been enacted that adopts federal filing deadlines for Delaware corporation income tax, partnership, and W-2 and 1099 series information returns. The due date for C corporation returns ...
DC - Online agreement for taxpayers to pay off tax debt discussed
The District of Columbia’s Office of Tax and Revenue (OTR) has issued a press release informing personal and corporate income taxpayers about the OTRt’s "Online Payment Agreement"&nbs...
The District of Columbia’s Office of Tax and Revenue (OTR) has issued a press release informing personal and corporate income taxpayers about the OTRt’s "Online Payment Agreement"&nbs...
FL - IRC conformity legislation, other changes enacted
Legislation has been enacted that updates the Internal Revenue Code (IRC) tie-in date for purposes of computing Florida corporate income tax liability from January 1, 2016, to January 1, 2017. The ame...
Legislation has been enacted that updates the Internal Revenue Code (IRC) tie-in date for purposes of computing Florida corporate income tax liability from January 1, 2016, to January 1, 2017. The ame...
GA - Average retail sales prices for prepaid local tax revised
A sales tax bulletin issued by the Georgia Department of Revenue lists the average retail sales prices used to calculate prepaid local tax applicable to sales of motor fuel for highway use for the per...
A sales tax bulletin issued by the Georgia Department of Revenue lists the average retail sales prices used to calculate prepaid local tax applicable to sales of motor fuel for highway use for the per...
HI - Change in mandatory tax filing and payment frequency announced
The Hawaii Department of Taxation (DOT) has announced changes to certain taxpayers’ mandatory general excise tax; transient accommodations tax; and rental motor vehicle, tour vehicle, and car-sh...
The Hawaii Department of Taxation (DOT) has announced changes to certain taxpayers’ mandatory general excise tax; transient accommodations tax; and rental motor vehicle, tour vehicle, and car-sh...
ID - Estimates of 2017 property taxes available for certain counties
Residents in 22 Idaho counties may estimate their 2017 property taxes by visiting the State Tax Commission’s website and using the online calculator to estimate what they owe. The estimate may n...
Residents in 22 Idaho counties may estimate their 2017 property taxes by visiting the State Tax Commission’s website and using the online calculator to estimate what they owe. The estimate may n...
IL - IRS settlement agreement triggered federal adjustment notice obligations for indirect partners
The Illinois Appellate Court affirmed the decision of the Independent Tax Tribunal granting a motion for summary judgment to the Department of Revenue against personal income taxpayers because they fa...
The Illinois Appellate Court affirmed the decision of the Independent Tax Tribunal granting a motion for summary judgment to the Department of Revenue against personal income taxpayers because they fa...
IN - Bulletin regarding credit for contributions to a scholarship-granting organization updated
The Indiana Department of Revenue has updated its information bulletin that discusses the school scholarship tax credit available against the personal and corporate income taxes, insurance premiums ta...
The Indiana Department of Revenue has updated its information bulletin that discusses the school scholarship tax credit available against the personal and corporate income taxes, insurance premiums ta...
IA - Taxpayer not entitled to capital gain deduction
A capital gains deduction claimed on an Iowa personal income tax return was properly disallowed because the taxpayer had not held the land for the requisite 10 year period and the sale was strictly a ...
A capital gains deduction claimed on an Iowa personal income tax return was properly disallowed because the taxpayer had not held the land for the requisite 10 year period and the sale was strictly a ...
KS - Legislature overrides veto, enacts income tax rate increase in Kansas
The Kansas Legislature has overridden Gov. Sam Brownback’s veto of a bill that makes a number of changes to personal income taxes, including repealing the exemption for non-wage business income ...
The Kansas Legislature has overridden Gov. Sam Brownback’s veto of a bill that makes a number of changes to personal income taxes, including repealing the exemption for non-wage business income ...
KY - 2017 legislation summarized, other matters discussed
The May issue of the Kentucky Tax Alert provides a summary of legislation enacted in 2017 that impacts the Kentucky Department of Revenue administration of taxes, including H.B. 284 that mad...
The May issue of the Kentucky Tax Alert provides a summary of legislation enacted in 2017 that impacts the Kentucky Department of Revenue administration of taxes, including H.B. 284 that mad...
LA - Flat tax bills pass house
The Louisiana House of Representatives has passed two bills that would, if enacted, change the corporate and personal income tax rates from graduated rates to flat rates. The corporate income tax flat...
The Louisiana House of Representatives has passed two bills that would, if enacted, change the corporate and personal income tax rates from graduated rates to flat rates. The corporate income tax flat...
ME - Legislation amends military retirement pay deductions, calculation of educational opportunity credit, and other provisions
Maine Gov. Paul LePage has signed legislation that makes several technical changes to the state’s personal income tax laws. Among other things, the legislation:clarifies that the military retire...
Maine Gov. Paul LePage has signed legislation that makes several technical changes to the state’s personal income tax laws. Among other things, the legislation:clarifies that the military retire...
MD - Nonprofit exemption certificate renewal applications issued
The Maryland Comptroller’s office has released sales and use tax exemption certificate renewal applications for nonprofit organizations with certificates that expire on September 30, 2017. The d...
The Maryland Comptroller’s office has released sales and use tax exemption certificate renewal applications for nonprofit organizations with certificates that expire on September 30, 2017. The d...
MA - Changes to filing due dates for partnership and corporate income tax returns announced
The Massachusetts Department of Revenue has issued a Technical Information Release (TIR) explaining supplemental budget legislation that enacted changes to the filing due dates for Massachusetts partn...
The Massachusetts Department of Revenue has issued a Technical Information Release (TIR) explaining supplemental budget legislation that enacted changes to the filing due dates for Massachusetts partn...
MI - Michigan supreme court denies review of renaissance zone credit case
On June 7, 2017, the Michigan Supreme Court issued an order denying an application for leave to appeal in Andersons Albion Ethanol, LLC v. Department of Treasury, Michigan Court of Appeals, No. 3...
On June 7, 2017, the Michigan Supreme Court issued an order denying an application for leave to appeal in Andersons Albion Ethanol, LLC v. Department of Treasury, Michigan Court of Appeals, No. 3...
MN - Specifications for electronically submitting W-2 information revised
For personal income withholding tax purposes, the Minnesota Department of Revenue has revised a guidance document that explains how to electronically submit copies of W-2 information to the department...
For personal income withholding tax purposes, the Minnesota Department of Revenue has revised a guidance document that explains how to electronically submit copies of W-2 information to the department...
MS - Tax appeal bonds were recoverable costs
A circuit court erred when it denied a Mississippi property taxpayer’s motion for the cost of tax appeal bond premiums because "costs" mandated by the statute include the bond premiums...
A circuit court erred when it denied a Mississippi property taxpayer’s motion for the cost of tax appeal bond premiums because "costs" mandated by the statute include the bond premiums...
MO - Local tax rate changes announced
The Missouri Department of Revenue has released the following local sales and use tax rate changes, effective July 1, 2017. The releases also list the new rates for each city and special district affe...
The Missouri Department of Revenue has released the following local sales and use tax rate changes, effective July 1, 2017. The releases also list the new rates for each city and special district affe...
MT - Intangible land value exemption enacted
For Montana property tax purposes, an intangible land value assistance program has been created for certain residential property when land value is disproportionately higher than the value of associat...
For Montana property tax purposes, an intangible land value assistance program has been created for certain residential property when land value is disproportionately higher than the value of associat...
NE - Local rate changes and municipal boundary changes announced
The Nebraska Department of Revenue has announced that beginning October 1, 2017, the village of Lawrence will impose a 1% local sales and use tax. Also, the village of Shelton will discontinue its 1% ...
The Nebraska Department of Revenue has announced that beginning October 1, 2017, the village of Lawrence will impose a 1% local sales and use tax. Also, the village of Shelton will discontinue its 1% ...
NV - Private party transfers of firearms discussed
The Nevada Department of Taxation has issued a sales and use tax bulletin providing information for retailers who perform background checks for private party transfers of firearms. The bulletin conclu...
The Nevada Department of Taxation has issued a sales and use tax bulletin providing information for retailers who perform background checks for private party transfers of firearms. The bulletin conclu...
NH - Credit for donations to scholarship organizations amended
New Hampshire has amended its credit against the business profits tax and the business enterprise tax for donations to scholarship organizations. The amendments extend the due date that a business has...
New Hampshire has amended its credit against the business profits tax and the business enterprise tax for donations to scholarship organizations. The amendments extend the due date that a business has...
NJ - Bulletin on taxability of restaurants revised
The New Jersey Division of Taxation has revised a bulletin explaining the sales and use tax rules that apply to restaurants. Businesses that sell prepared food and beverages, such as restaurants, tave...
The New Jersey Division of Taxation has revised a bulletin explaining the sales and use tax rules that apply to restaurants. Businesses that sell prepared food and beverages, such as restaurants, tave...
NM - Affiliate nexus rule vetoed, deductions and exemptions clarified
Gov. Susana Martinez vetoed numerous provisions in a bill intended to make significant sales and use tax reforms, leaving amendments that clarify exemptions and deductions for gross receipts tax and g...
Gov. Susana Martinez vetoed numerous provisions in a bill intended to make significant sales and use tax reforms, leaving amendments that clarify exemptions and deductions for gross receipts tax and g...
NY - Dismissal of untimely request for administrative review upheld
The New York Tax Appeals Tribunal found that a taxpayer’s petition contesting a sales and use tax assessment following the issuance of a conciliation order was properly dismissed because it was ...
The New York Tax Appeals Tribunal found that a taxpayer’s petition contesting a sales and use tax assessment following the issuance of a conciliation order was properly dismissed because it was ...
NC - Individual income tax, pass-through entities, and withholding bulletin updated
The North Carolina Department of Revenue has updated a publication discussing the administrative interpretation and application of North Carolina income tax laws to individuals and pass-through entity...
The North Carolina Department of Revenue has updated a publication discussing the administrative interpretation and application of North Carolina income tax laws to individuals and pass-through entity...
ND - Internet access charges, expired or expiring exemptions, 2017 legislation discussed
A North Dakota Office of State Tax Commissioner newsletter reminds taxpayers that Internet access charges are exempt from sales and use tax, effective July 1, 2017. The newsletter also reminds taxpaye...
A North Dakota Office of State Tax Commissioner newsletter reminds taxpayers that Internet access charges are exempt from sales and use tax, effective July 1, 2017. The newsletter also reminds taxpaye...
OH - Third quarter of 2017 wholesale prices of gasoline for PAT calculations released
The Ohio Department of Taxation has issued a release showing the statewide average wholesale prices of a gallon of unleaded regular gasoline at $1.473 (previously, $1.439), diesel fuel at $1.572 (prev...
The Ohio Department of Taxation has issued a release showing the statewide average wholesale prices of a gallon of unleaded regular gasoline at $1.473 (previously, $1.439), diesel fuel at $1.572 (prev...
OK - Exemptions for national guard association, marine corps league created
Effective July 1, 2018, Oklahoma legislation creates sales and use tax exemptions for sales of tangible personal property or services to or by the National Guard Association of Oklahoma and the Marine...
Effective July 1, 2018, Oklahoma legislation creates sales and use tax exemptions for sales of tangible personal property or services to or by the National Guard Association of Oklahoma and the Marine...
OR - Unitary group determination amended
Oregon has enacted legislation for purposes of the corporate excise (income) tax that allows the Department of Revenue to consider the role of foreign affiliates when making the determination of wheth...
Oregon has enacted legislation for purposes of the corporate excise (income) tax that allows the Department of Revenue to consider the role of foreign affiliates when making the determination of wheth...
PA - Refund appeal schedules, hotel occupancy tax discussed
A Pennsylvania Department of Revenue newsletter discusses board of appeals schedules for sales and use tax refund petitions and the hotel occupancy tax.Refund Appeal SchedulesThe department’s bo...
A Pennsylvania Department of Revenue newsletter discusses board of appeals schedules for sales and use tax refund petitions and the hotel occupancy tax.Refund Appeal SchedulesThe department’s bo...
RI - New ID numbers assigned to retailers and permit holders
The Rhode Island Division of Taxation (DOT) announced that it has assigned individualized account identification (ID) numbers to retailers and other sales tax permit holders that will take effect July...
The Rhode Island Division of Taxation (DOT) announced that it has assigned individualized account identification (ID) numbers to retailers and other sales tax permit holders that will take effect July...
SC - Membership fees for bookseller’s discount program are taxable
Membership fees charged by a discount bookseller for discounts and free shipping on purchases were subject to South Carolina sales tax because the fees were properly included in the retailer’s g...
Membership fees charged by a discount bookseller for discounts and free shipping on purchases were subject to South Carolina sales tax because the fees were properly included in the retailer’s g...
SD - New municipal tax rate changes announced
The South Dakota Department of Revenue has released a bulletin that announces upcoming municipal sales tax rate changes. Effective July 1, 2017, the following rate changes will be imposed:— Dant...
The South Dakota Department of Revenue has released a bulletin that announces upcoming municipal sales tax rate changes. Effective July 1, 2017, the following rate changes will be imposed:— Dant...
TN - Refunds available on certain items for sevier county residents affected by wildfires
As previously reported, Sevier County residents whose primary and/or secondary residence was damaged or destroyed as a result of the wildfires that occurred during November 28 through December 9, 2017...
As previously reported, Sevier County residents whose primary and/or secondary residence was damaged or destroyed as a result of the wildfires that occurred during November 28 through December 9, 2017...
TX - Texas amends deadline for petition for redetermination, refund claim hearing
Beginning September 1, 2017, a taxpayer’s petition for redetermination of corporation income tax, personal income tax, sales and use tax, or other tax liability computed by the Texas Comptroller...
Beginning September 1, 2017, a taxpayer’s petition for redetermination of corporation income tax, personal income tax, sales and use tax, or other tax liability computed by the Texas Comptroller...
UT - Appeal dismissed as untimely
A Utah taxpayer’s appeal of property tax assessments of its centrally assessed mining equipment was dismissed because the appeal was filed beyond the statutory deadline. Under Utah law, a proper...
A Utah taxpayer’s appeal of property tax assessments of its centrally assessed mining equipment was dismissed because the appeal was filed beyond the statutory deadline. Under Utah law, a proper...
VT - Provision extending trade-in allowance period on certain vehicle buybacks enacted
Vermont legislation provides that, for motor vehicle purchase and use tax purposes, the three-month limitation on the trade-in allowance period in which to reduce the taxable cost of a motor vehicle b...
Vermont legislation provides that, for motor vehicle purchase and use tax purposes, the three-month limitation on the trade-in allowance period in which to reduce the taxable cost of a motor vehicle b...
VA - Filing reminders issued
The Virginia Department of Taxation has issued filing reminders for corporate income tax returns (Form 500) and for pass-through entity returns (Form 502). Both forms are due electronically on or befo...
The Virginia Department of Taxation has issued filing reminders for corporate income tax returns (Form 500) and for pass-through entity returns (Form 502). Both forms are due electronically on or befo...
WA - Auto manufacturer incentives were taxable
An automobile dealer’s taxable gross income for purposes of the Washington service and other activities business and occupation (B&O) tax included certain manufacturer incentives because the...
An automobile dealer’s taxable gross income for purposes of the Washington service and other activities business and occupation (B&O) tax included certain manufacturer incentives because the...
WV - Wardensville local tax not adopted
Previous notifications from the West Virginia State Tax Department erroneously indicated that Wardensville had adopted a municipal sales and use tax that the Department would begin collecting effectiv...
Previous notifications from the West Virginia State Tax Department erroneously indicated that Wardensville had adopted a municipal sales and use tax that the Department would begin collecting effectiv...
WI - Guidance for electrical contractors updated
The Wisconsin Department of Revenue has updated its sales and use tax guidance for electrical contractors. Important changes to the guidance include:Effective for contracts entered into on and after O...
The Wisconsin Department of Revenue has updated its sales and use tax guidance for electrical contractors. Important changes to the guidance include:Effective for contracts entered into on and after O...
WY - Vehicle towing and tow-related services discussed
A Wyoming tax bulletin addresses the sales tax treatment of various services performed in conjunction with nontaxable tow services. A tow service involving a vehicle being moved from one location to a...
A Wyoming tax bulletin addresses the sales tax treatment of various services performed in conjunction with nontaxable tow services. A tow service involving a vehicle being moved from one location to a...
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