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What is an executive level appeal?

Cases involving the following issues may be designated as an executive level appeal:

    • Issues for which no precedent has been established, or
    • Issues that have industry-wide significance or impact.

Only a limited number of cases are treated as executive level appeals. A case accepted for executive level treatment will be heard by both an ALJ and a designee of the Director. This is the only appeal type where the taxpayer and Operating Division receive a proposed decision with 30 days to respond, followed by a final decision.

How does a case become executive level?

You may request Executive level review or the Appeals Division may designate it based on the complexity of the issues.

Mainstream appeals

Decisions that are not designated small claims or executive level are called mainstream appeals. They are usually decided within one year of filing your petition.


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