This section describes the types of notices used in the State tax appeal and collection
process and the appropriate appeal actions to be taken at each stage.
Proposed Assessment Notice
This notice is generated as a courtesy. It signifies that the Department has obtained
or discovered information from the return or other sources that indicate additional
tax may be due.
To Dispute A Notice Of Proposed Assessment:
Complete a Protest of Proposed Assessment or Refund Denial form.
Click here to download the form and follow the instructions. Your protest form must be postmarked
within 30 days of the notice date.
DOR will notify you that the protest has been either granted or denied. If DOR grants the protest of a proposed
assessment, the assessment will be withdrawn. If DOR grants the protest of a refund denial, we will issue the refund.
If DOR denies the protest of a proposed assessment, DOR will issue an Official Assessment and
Demand for Payment and notify you of the assessment amount, subject to the right to appeal as provided by law. If
DOR denies the protest of a refund denial, you will also have the right to appeal to either the Georgia Tax Tribunal
or superior court.
Official Assessment and Demand for Payment Notice
This notice is the official ruling of the Department pertaining to a person's tax
liability. Payment in the full amount of tax, penalty and interest or an appeal,
if you still disagree, must be made within 30 days. You may appeal an official
assessment to either the Georgia Tax Tribunal or the appropriate superior court.
If you fail to pay or appeal this official assessment, a state tax execution may be issued
pursuant to O.C.G.A. § 48-3-1. Further, as provided by O.C.G.A. §
48-16-10, a 20% cost of collection fee will be added and, collection of the liability
may then be enforced through the legal processes of attachment, garnishment or levy
as authorized by O.C.G.A. § 48-2-55.
To Dispute an Official Assessment:
You must file an appeal with either the Georgia Tax Tribunal or in the appropriate superior
court within 30 days of the official assessment’s issuance date.
Georgia Tax Tribunal (GTT)
The GTT hears and decides certain state tax disputes and is completely separate from and totally
independent of DOR. Decisions of the Tribunal (except small claims cases) can be appealed to the Superior
Court of Fulton County.
GTT’s Small Claims Division handles appeals where the amount of tax and penalties in controversy is
less than either $15,000 for income tax cases or $50,000 for all other tax types. Decisions in small claims
cases are final and cannot be appealed.
To file an appeal with the GTT, complete a Georgia Tax Tribunal Petition by downloading the form from either
You can also appeal an official assessment to the appropriate superior court. To do so, your appeal must
satisfy certain legal procedural requirements and be accompanied by either a surety bond in an amount that
equals the amount in dispute, or evidence of your owning equity in real estate in Georgia in an amount that equals
or exceeds the amount in dispute. It is highly recommended that you retain legal counsel for an appeal to superior court.
Issuance of State Tax Execution Notice
This notice advises you that a state tax execution has been issued against you and may be recorded with the appropriate superior
court clerk’s office. The Department of Revenue has the authority to enforce collection of this debt by garnishment, levy, and
other types of enforced collection activities.
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