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Last Updated: 1/3/2019


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​An appeal with the Minnesota Department of Revenue can be one of the following:

  • An administrative review by the Appeals Unit in the Appeals and Legal Services Division
  • An administrative review by the Administrative Review Officer in our Collection Division
  • An appeal filed in Minnesota Tax Court or Small Claims Division of Tax Court
  • An administrative hearing held by the Office of Administrative Hearings held in front of an administrative law judge at the Office of Administrative Hearings
  • A reconsideration review by our Taxpayer Rights Advocate (TRA) 

When we send a letter informing you of possible enforced collection actions, it explains what type of appeal you may request. 

Appeal Options

The table below lists the letters we send that include appeal options.  

Notice or Letter

​Appeals Unit

​Administrative Review

​Tax Court

​Administrative Hearing

​Taxpayer Rights Advocate

Order Assessing Successor Liability​ x​ ​x
Order Denying Abatement Request​ x x​​
Denial of Compromise Proposal​ x
Order Assessing Liability for Failure to Honor Levy​ x x​
Order Assessing Fiduciary Liability​ x x​
Order Assessing Transferee Liability​ x x​
Order Assessing Personal Liability​ x x​
Tax Orders Issued by Audit Division​ x​ ​x
Order Changing Withholding Allowance​ x​
Notice of Commissioner Filed Returns​ x​
Jeopardy Assessment and Collection​ x ​x
Intent to Revoke Sales Tax Permit​ x​
Intent to Revoke License​ x​
Notice of Requirement for License Clearance​ x​
Payment Agreement Denial​ x​