Virginia Code Title 58.1. Taxation § 58.1-1835. Abatement of any tax, interest, and penalty attributable to erroneous written advice by the Department

1. The written advice was reasonably relied upon by the taxpayer and was in response to a specific written request by the taxpayer;

2. The portion of the penalty or tax did not result from a failure by the taxpayer to provide adequate or accurate information; and

3. 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.