Amends TCA Title 67, Chapter 1.

Present law provides that if the commissioner of revenue changes the department of revenue's policy as to the taxability of any privilege, such policy change must be applied to the exercise of such privileges occurring after the date of such policy change, unless otherwise provided by law. This bill adds that a taxpayer may rely on guidance published by the commissioner of revenue concerning the taxability of a privilege. This bill further specifies that, if the commissioner changes the guidance, a taxpayer who relied on the prior guidance is not liable for any additional tax, penalty, or interest accrued before the guidance was changed and was unpaid because of the taxpayer's reasonable reliance on the prior guidance. Additionally, this bill specifies that if a taxpayer is audited by or requests specific advice from the department and receives erroneous audit findings or advice, then the taxpayer is not liable for any assessment of additional tax, interest, or penalty attributable to the erroneous finding or advice, to the extent that the taxpayer reasonably relied on the finding or advice, the additional assessment did not result from the taxpayer failing to provide adequate or accurate information, and the department provided the finding or advice in writing or the department's records establish the taxpayer received erroneous verbal advice.