Rule 100 letter ruling review

Review of an adverse tax ruling issued by the Tax Information & Education (TI&E) section:

What is a tax ruling review?

It is an administrative review limited to a binding tax ruling issued to you by the Department’s TI&E section. You may request a review of a ruling when you believe that the ruling contains a legal or factual error.

When can I request a review of a tax ruling?

You may petition for a review of an adverse tax ruling within 30 days of the issuance of the ruling.

Will I have a hearing?

No. The review is limited to the documents and records reviewed by TI&E, any information you provide with the petition and your arguments as to why the tax ruling is in error.

How will I know when the review is concluded?

You will receive a written determination.

What if I disagree with the determination?

The determination is the final decision of the department and is not eligible for reconsideration or appealable to the Board of Tax Appeals. You can ask for a new tax ruling from the TI&E section if the facts related to your business change.