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party to an application to correct an assessment merely because the Tax Commissioner has • ruled on it. (2)Suspension ofpavment of disputed amount of tax due upon taxpayer's notice of intent to initiate judicial review. Upon receipt of a notice of intent to file an application for iudicial review of a determination of the Tax Commissioner, and upon payment of the amount of the tax that is not in dispute together with any penalty and interest then due with respect to such undisputed portion of the tax the treasurer or other collection official shall further suspend collection activity while the court retains iurisdiction unless the court, upon appropriate motion after notice and an opportunity to be heard, determines that (i) the taxpayer's application forjudicial review is frivolous, as defined in this section: (ii) collection would be Jeopardized by delay, as defined in this section: or (iii) suspension of collection would cause substantial economic hardship to the locality. For purposes of determining whether substantial economic hardship to the locality would arise from a suspension of collection activity, the court shall consider the cumulative effect of then -pending appeals filed within the locality by different taxpayers that allege common claims or theories of relief. Upon a determination that the appeal is frivolous that collection may be ieopardized by delay, or that suspension of collection would result in substantial economic hardship to the locality, the court may require the taxpayer to pay the amount in dispute or a portion thereof, or to provide surety for payment of the amount in dispute in a form acceptable to the courtNo suspension of collection activity shall be required if the application for judicial review fails to identify with particularity the amount in dispute. The requirement that collection activity be suspended shall cease unless an application for judicial review is filed and served on the necessary parties within 30 days of the service of the notice of intent to file such application The suspension of collection activity authorized by this subdivision shall not be applicable to any appeal of a • local license tax that is initiated by the direct filing of an action pursuant to Virginia Code $58.1-3984 without prior exhaustion of administrative appeals provided by this section 3)Suspension ofpavment of disputed amount of refund due upon localitv's notice of intent to initiate judicial review. Payment of any refund determined to be due pursuant to the determination of the Tax Commissioner shall be suspended if the locality assessing the tax serves upon the taxpayer, within 60 days of the date of the determination of the Tax Commissioner, a notice of intent to file an application for iudicial review of the Tax Commissioner's determination pursuant to Virginia Code §58.1-3984 and pays the amount of the refund not in dispute, including tax and accrued interest Payment of such refund shall remain suspended while the court retains iurisdiction unless the courtupon appropriate motion after notice and an opportunity to be heard determines that the locality's application for iudicial review is frivolous, as defined in this section No suspension of refund activi shall be permitted if the locality's application for iudicial review fails to identify with Particularity the amount in dispute. The suspension of the obligation to make a refund shall cease unless an application for iudicial review pursuant to Virginia Code 458.1-3984 is filed and served on the necessary parties within 30 days of the service of the notice of intent to file such application. Interest shall accrue in accordance with the provisions of City Code & 14-12 but no further penalty shall be imposed while collection action is suspended (h)Rulings Any taxpaver or authorized representative of a 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 facts relevant to the situation placed at issue 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 Page 5 of 8