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Last Updated: 12/14/2017

Appeal Rights

Administrative Appeals

You can request an administrative appeal if you disagree with the valuation order you receive from the department. Submit a written request for an administrative appeal within 30 days after the notice date of your order.

Your request needs to include the following information:

  • Your name and address
  • The date of the notice you are appealing
  • Your Minnesota Tax Identification Number
  • The assessment year involved
  • The findings in the order you disagree with and why
  • Your signature or that of your authorized representative (the person who is named on your Form REV187, Power of Attorney)

Please include any documents or information that supports your appeal such as:

  • Your complete list of issues/concerns and supporting documents
  •  Your proposed market value, including the methods you used to arrive at this amount
  •  Financial forecasts including, but not limited to, income, expense, and capital expenditures
  • An appraisal of the company (if one was performed)

Provide all the information listed above when requesting your administrative appeal. Without the requested information, the department will not be able to review your appeal in the time provided. 

The department will schedule a telephone or in person conference with you within 20 days of your appeal request. You can choose not to participate in a conference. The department will issue an appeal determination within 30 days of the appeal conference. The appeal determination is appealable to Minnesota Tax Court and the department will provide you with appeal information at that time.

Settlement Agreement

The commissioner may settle any matter under administrative appeal when it appears to be in the best interest of the state. The settlement agreement must be in writing and signed by the commissioner and the company or the company’s authorized representative. Given the deadlines for issuing appeal determinations, the company should plan to have someone with authority to sign a settlement agreement available during the appeal process.

The agreement is final and conclusive, and except upon a showing of fraud, malfeasance, or misrepresentation of a material fact, the case may not be reopened as to the matters agreed upon.

Tax Court Appeals

If you disagree with the valuation order or appeal determination, you can appeal to Tax Court within 60 days after the Notice Date of your order or appeal determination. You may request a 30-day extension from the court if you believe you have good cause for the extension. You can find more information on your order or appeal determination.

Settlement agreements reached during administrative appeal are final and are not appealable to Tax Court. If you file both an appeal with Tax Court and an administrative appeal with the department, we will dismiss the administrative appeal.