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Home / File & pay / Reviews and appeals / Rule 100 further appeal rights
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Rule 100 further appeal rights

Can I appeal a final decision of the Department of Revenue?

You may appeal a final decision involving an assessment or a refund issued by the Administrative Review and Hearings Division to the Board of Tax Appeals (BTA). An appeal with the BTA must be filed within 30 days of the final decision. The Department of Revenue does not have the authority to extend this filing date.

Do I have to pay the tax assessment before a further appeal?

Payment is not required before filing an appeal with the BTA, but the Department can proceed with collection efforts if payment is not made by the due date.

A stay of collection may be granted at the discretion of the Department. If you need a stay, you should contact the Department's Compliance Division. Contact the local office nearest your business. For a stay of collection, you must file a suitable bond, guaranteed by a specific, authorized surety insurer with the Department. The bond must be in an amount, which is up to twice the amount on which the stay is requested, plus interest, and must run for the duration of the requested stay.

Can I appeal directly to Superior Court?

Yes, but you must first pay any amounts due. An appeal for refund can be filed directly with the Thurston County Superior Court. The appeal must be filed no later than 4 years following the payment or 30 days after the final decision, whichever is later.

Are further appeals available beyond Superior Court?

Yes. Both you and the Department can appeal to the Court of Appeals or to the Washington Supreme Court.

More information

What Department actions are reviewable?

Rule 100 reviews

  • Starting a Rule 100 review
  • Extensions for requesting a Rule 100 review
  • Rule 100 Hearings
  • Rule 100 Decisions
  • Rule 100 Small claims review
  • Rule 100 Letter ruling review
  • Rule 100 Executive level review
  • Rule 100 Reconsideration requests
  • Rule 100 Further appeal rights
  • Rule 100 Settlements
  • Publishing your Rule 100 decision

APA Appeals

  • What is an APA appeal?
  • Revocation of your business license
  • Reseller permit appeals
  • Unclaimed property appeals
  • Other APA appeals

Other information

  • Authorizing law
  • Contact information
  • Taxpayer Survey
  • Settlement Track created to make settlement process quicker
  • Non-acquiescence statements
  • Statistics
  • Reseller permits

What Department actions are reviewable?

Rule 100 reviews

  • Starting a Rule 100 review
  • Extensions for requesting a Rule 100 review
  • Rule 100 Hearings
  • Rule 100 Decisions
  • Rule 100 Small claims review
  • Rule 100 Letter ruling review
  • Rule 100 Executive level review
  • Rule 100 Reconsideration requests
  • Rule 100 Further appeal rights
  • Rule 100 Settlements
  • Publishing your Rule 100 decision

APA Appeals

  • What is an APA appeal?
  • Revocation of your business license
  • Reseller permit appeals
  • Unclaimed property appeals
  • Other APA appeals

Other information

  • Authorizing law
  • Contact information
  • Taxpayer Survey
  • Settlement Track created to make settlement process quicker
  • Non-acquiescence statements
  • Statistics
  • Reseller permits
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Sales & use tax rates

Tax incentives

Business & occupation tax

Retail sales tax

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Invite a speaker to your group 

Request a visit from a tax consultant

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