Rule 100 reconsideration requests


Reconsideration is used when you identify a mistake of law or fact made in the determination that could change the result of your decision. This process is available for mainstream cases only.

Petition due date

The written petition for reconsideration must be postmarked or delivered by the due date shown on the decision (plus any extensions granted prior to the due date).

Late filing

When the petition for reconsideration is not filed on time, the decision becomes final. If you do not pay the assessment by the due date, additional interest and penalties will accrue.

Filing an extension

Yes. An extension may be granted on the same grounds as other petitions. See Extensions.

What to include

A petition for reconsideration must identify specific mistakes in law or fact that requires reconsideration. If you fail to specify mistakes of law or fact, your petition for reconsideration may be summarily dismissed without a hearing.

You must include any new documents and explanations with your petition for reconsideration. If your petition for reconsideration is accepted, it will be assigned to the original Tax Revenue Officer (TRO) so that any errors in fact or law can be corrected and new arguments and information addressed.

Reconsideration hearing

Most petitions for reconsideration can be decided without a hearing. The TRO may decide to hold a reconsideration hearing in some cases.

Reconsideration decision

The TRO will issue a written reconsideration decision and send it to you and your authorized representative. If your representative has authorized the Department to communicate by email, then we will send it to the representative by email. Otherwise, we will send the decision to your representative by regular US postal mail.

If you have a My DOR account, we will send your copy of the decision to you through your My DOR account. If you do not have a My DOR account, then we will either send it to you by email, if you have previously authorized email communication, or by regular US postal mail.