The Department of Revenue's Office of Appeals works with taxpayers to resolve tax disputes involving proposed or final tax assessments, amended returns and other matters. Our mission is to resolve disputes in an informal, expeditious and consistent manner, and to make determinations as to the correct amount of tax at issue.
Depending on the type of appeal, the Office of Appeals will conduct a conference or a hearing with the taxpayers to listen, ask questions, request additional information or documentation, if necessary, and make a determination as to how the dispute should be resolved.
Sometimes, the answer to how a tax dispute should be decided is not always clear. In these situations, the Office of Appeals has the authority to settle tax disputes by accepting less than the full amount of tax in dispute. The Department of Revenue will consider settling a dispute if it is in the best interests of the Commonwealth to accept a lesser amount of tax.
Taxpayers may request settlement consideration at any time during the appeals process. The conference, hearing, and settlement processes are combined at the Office of Appeals to afford taxpayers a single, integrated forum to resolve their disputes.
Administrative Procedures and Directives
- AP 628: Resolution of Disputes at the Office of Appeals
- AP 633: Guidelines for the Waiver and Abatement of Penalties
- AP 635: Early Mediation Program
- AP 636: Appeal Process for Denial or Partial Denial of Applications for Massachusetts Brownfields Tax Credit
- Directive 12-7: Section 35A Penalty for Underpayment of Tax Required to be Shown on Return