Payment under protest preserves refund entitlement and suspends the refund limitation while appeal proceedings continue.

Payment under protest preserves an assessee's refund entitlement and suspends the ordinary one year refund limitation while an appeal is pending; it requires a written letter of protest with acknowledgement, annotation of invoices and returns, and appropriate ledger entries, and limits refunds to amounts not passed on to buyers under the doctrine of unjust enrichment.

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