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or partially ineffectual, proceedings to collect the tax for the • period in question. (c) Any person assessed with a local license tax as a result of an audit may apply within ninety (90) days of the determination by the Commissioner of the Revenue on an application pursuant to subsection (a) of this section to the Tax Commissioner for a correction of such assessment. The Tax Commissioner shall issue a determination to the taxpayer within ninety (90) days of receipt of the taxpayer's application, unless the taxpayer and the assessing official are notified that a longer period will be required. The application shall be treated as an application pursuant to Virginia Code Section 58.1-1821, as amended, and the Tax Commissioner may issue an order correcting such assessment pursuant to Virginia Code Section 58.1-1822, as amended. Following such an order, either the taxpayer or the assessing official may apply to the appropriate circuit court, pursuant to Virginia Code Section 58.1-3984, as amended. However, the burden shall be on the party making the application to show that the ruling of the Tax Commissioner is erroneous. Neither the Tax Commissioner nor the Department of Taxation shall be made a party to an application to correct an assessment merely because the Tax Commissioner has ruled on it. (d) On receipt of a notice of intent to file an appeal to the Tax Commissioner under subsection (c) of this section, the Commissioner of the Revenue shall notify the Treasurer of the • appeal. The Treasurer or the Commissioner of the Revenue shall suspend collection activity until a final determination is issued by the Tax Commissioner, unless the Commissioner of the Revenue determines that collection would be jeopardized by delay or that the taxpayer has not responded to a request for relevant information after a reasonable time. Interest shall accrue in accordance with the provisions of section 14-12 of this chapter, but no further penalty shall be imposed while collection action is suspended. The term "jeopardized by delay" shall have the same meaning as set forth in subsection (b) above. (e) Any taxpayer may request a written ruling regarding the application of a local license tax to a specific situation from the Commissioner of the Revenue. Any person requesting such a ruling must provide all the relevant facts for the situation and may present a rationale for the basis of an interpretation of the law most favorable to the taxpayer. Any misrepresentation or change in the applicable law or the factual situation as presented in the ruling request shall invalidate any such ruling issued. A written ruling may be revoked or amended prospectively if (i) there is a change in the law, a court decision, or the guidelines issued by the Department of Taxation upon which the ruling was based, or (ii) the Commissioner of the Revenue notifies the taxpayer of a change in the policy or interpretation upon which the ruling was based. However, any person who acts on a written ruling which later becomes invalid shall be deemed to have acted in good faith during • the period in which such ruling was in effect. Page 12 of 34