Public Comments for: HB2264 - Taxation, Department of; repealing Virginia Free File Tax program.
Last Name: fraser Locality: COVINGTON

I am against this bill which proposes to terminate the Virginia Free File program and replace it with a state-developed free tax filing program. Here are my reasons: Disruption of Existing Services: Terminating the Virginia Free File program, which has been in place and utilized by taxpayers, could disrupt services for those who rely on it, potentially causing confusion and inconvenience, similar to concerns about service continuity in Goldberg v. Kelly (1970). Cost and Development: Developing a new state-specific tax filing program involves significant costs, both in terms of initial development and ongoing maintenance. This could be seen as an inefficient use of state resources, echoing fiscal concerns from City of Richmond v. Virginia (1976) regarding government spending. Compatibility Issues: Ensuring the new program is compatible with the IRS Direct File program might be challenging, leading to potential technical issues or delays in implementation, akin to the integration problems discussed in American Electric Power Co., Inc. v. Connecticut (2011) regarding federal-state coordination. Privacy and Security: A state-run program might not have the same level of security infrastructure as established federal or private sector programs, raising privacy concerns similar to those in Carpenter v. United States (2018) about data protection. Efficiency and User Experience: The transition period until 2028 might leave taxpayers without a seamless filing experience, potentially degrading service quality during the interim, which could impact taxpayer satisfaction and compliance, reflecting service delivery critiques in Massachusetts v. EPA (2007). Federal Dependency: Relying on a memorandum of understanding with the IRS for program development could make the state program overly dependent on federal cooperation, potentially affecting Virginia's autonomy in tax administration, a concern similar to federalism issues in New York v. United States (1992). Loss of Private Sector Innovation: Ending the partnership with the Consortium for Virginia might reduce the innovation and competition that private sector involvement brings to tax filing services, potentially leading to a less dynamic and user-friendly state solution, paralleling the market impact concerns in Lochner v. New York (1905). I oppose this legislation due to the potential disruption of existing services, high development costs, compatibility challenges, privacy and security risks, impact on user experience, increased dependency on federal cooperation, and the loss of private sector innovation, advocating for maintaining or enhancing current partnerships rather than creating a new state-run system.

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