Maryland tax controversies.

A taxpayer who still disputes a Comptroller assessment or a refund denial files that appeal through the Online Appeal Request. That system states the appeal should be filed within 30 days of the date on the notice. The Comptroller reviews timeliness and whether the papers resolve the dispute before it schedules a hearing.

Maryland offer in compromise filings use Form MD 656 and Form MD 433-A. The Comptroller Offer in Compromise page and Form MD 656, checked August 28, 2026, do not list an application fee. The IRS lists a $205 application fee for most federal offers. That Comptroller page also states that receipt of a Maryland offer does not create a collections hold.

Maryland Tax Court review, when the notice opens it, runs from the Notice of Final Determination. Procedures citing Tax-General Article 13-508 and 13-510 state that the appeal must be filed within 30 days after that notice. Md. Code, Tax-General section 13-515 sets who may appear. An individual may appear without a lawyer, a partner may appear for a partnership, an officer may appear for a corporation, and any party may be represented by a lawyer admitted in Maryland. A federal credential such as an enrolled-agent license is not an appearance right there. Under Tax-General 13-510, if the Comptroller does not act on a refund claim within six months, the taxpayer may treat the claim as denied and appeal. The printed date controls. Do not use this page to calculate that deadline.

Official source: Comptroller Online Appeal Request
Official source: Comptroller Offer in Compromise
Official source: Form MD 656
Official source: Maryland Tax Court procedures
Official source: IRS offer in compromise

A federal change can become a Maryland bill. Under Tax-General section 13-409, when the IRS issues a final determination that increases federal taxable income reported on a federal return, the Comptroller assesses Maryland income tax on the resulting increase in Maryland taxable income. Within 90 days after the IRS issues that final determination, the taxpayer must submit a report of federal adjustment that includes a statement of the amount of the increase and, if the taxpayer contends the federal determination is erroneous, an explanation of why. That report is the taxpayer's to file whether or not a Comptroller notice arrives, and the 90 days run from the IRS final determination. Do not use this page to calculate that deadline. For personal income tax, the Comptroller says that when it believes a Maryland return may need adjustment because of changes the IRS made to the federal return, it sends a notice showing the impact on the Maryland income tax return.

The federal change itself is contested with the IRS and, after a Notice of Deficiency, in the U.S. Tax Court. Under 26 U.S.C. section 6213(a), the taxpayer may petition that court within 90 days after the notice is mailed, or 150 days if it is addressed to a person outside the United States, and a petition filed by the last date the IRS specifies in the notice is treated as timely. The Tax Court lists Baltimore as a place of trial with no permanent courtroom, and says to see the notice of trial for the address. Its courthouse is at 400 2nd St NW in Washington, DC. Mr. Powell handles the federal matter, whether an examination, an appeal, or a Tax Court case, and the Maryland report or Comptroller notice that follows it, from the Washington, DC office.

Tax-General section 13-409, the Comptroller's Tax Tip #36 (revised April 3, 2023), 26 U.S.C. section 6213(a) (2024 United States Code edition), and the Tax Court's places of trial were checked on mgaleg.maryland.gov, marylandcomptroller.gov, GovInfo, and ustaxcourt.gov on October 6, 2026.

Official source: Md. Code, Tax-General 13-409, federal adjustments
Official source: Comptroller of Maryland, Tax Tip #36
Official source: 26 U.S.C. 6213(a)
Official source: U.S. Tax Court, places of trial