1. Which Agency Issued Your Tax Notice?
The agency name and notice type establish the starting point. Distinguish a request for records, a proposed adjustment, and a formal determination before choosing a response.
Federal and State Tax Notices
The IRS administers federal income and employment taxes. An examination letter requests information, while a statutory notice of deficiency generally provides a separate opportunity to petition the U.S. Tax Court.
The New York State Department of Taxation and Finance handles state income, corporation, and sales taxes. Qualifying notices offer review through the Bureau of Conciliation and Mediation Services, or BCMS, or the Division of Tax Appeals.
Property Assessments and Tax Bills
For property within City of Rochester boundaries, the Bureau of Assessment handles valuation issues. Questions about missing payments or account balances belong with the collecting office identified on the bill.
An assessment challenge concerns the property’s assessed value or another legally recognized assessment error. A payment inquiry does not replace the formal assessment-review process.
2. What Should You Check before Responding?
A response should explain the disputed item and connect it to relevant evidence. Keep the complete notice, attachments, envelope, and proof of earlier submissions so the record shows both the disagreement and its procedural history.
Dates, Instructions, and the Named Taxpayer
Record the affected tax periods, deadline, and submission method. Informal discussions do not automatically extend a protest or petition deadline.
Check whether the notice names an individual, business, or person allegedly responsible for business taxes. A response for the company does not necessarily challenge a separate assessment against its owner or employee.
Records That Address the Disagreement
Select documents that explain the proposed adjustment rather than sending unrelated financial information. IRS audit defense may involve reconciling reported figures with the evidence behind them.
| Issue | Useful Records | Main Question |
|---|---|---|
| Income | Returns, W-2s, 1099s, bank records | Is income duplicated or misclassified? |
| Business expenses | Receipts, invoices, contracts | Does the evidence support the deduction? |
| Sales tax | POS reports, sales journals, exemption certificates | Do taxable sales match the return? |
| Payment credit | Confirmations, canceled checks | Was payment credited correctly? |
| Property value | Property inventory, comparable sales, appraisal | Does the assessment reflect accurate facts? |
Income
- Useful RecordsReturns, W-2s, 1099s, bank records
- Main QuestionIs income duplicated or misclassified?
Business expenses
- Useful RecordsReceipts, invoices, contracts
- Main QuestionDoes the evidence support the deduction?
Sales tax
- Useful RecordsPOS reports, sales journals, exemption certificates
- Main QuestionDo taxable sales match the return?
Payment credit
- Useful RecordsConfirmations, canceled checks
- Main QuestionWas payment credited correctly?
Property value
- Useful RecordsProperty inventory, comparable sales, appraisal
- Main QuestionDoes the assessment reflect accurate facts?
A deposit alone may not show whether money represents sales, a loan, or a transfer. Reviewing business tax records means connecting transactions to returns and explaining material differences.
3. Which Review or Appeal Route Applies?
Administrative responses, tribunal petitions, and assessment challenges have separate filing requirements. The notice and governing law determine the available route, deadline, and whether mailing or actual receipt controls.
IRS Appeals and Tax Court
For an eligible administrative appeal, send the protest to the IRS address specified in the letter. Do not send it directly to the Independent Office of Appeals unless the instructions require that route.
Under IRC §6213(a), a deficiency petition generally must reach the filing stage within 90 days after mailing of the notice, or 150 days if addressed to a person outside the United States, subject to applicable filing rules. The petition goes to the U.S. Tax Court, including through DAWSON for electronic filing, rather than to the IRS.
These periods do not apply to every IRS notice. Continuing to exchange documents with an examiner does not itself extend the court deadline.
BCMS and Division of Tax Appeals
A qualifying state notice may permit a BCMS conference request or a petition to the Division of Tax Appeals. Many income-tax deficiency and sales-tax determination notices carry a 90-day protest period, but the particular notice and applicable law control.
DTA hearings generally occur in Albany, New York City, and Rochester. Current TA-100 instructions direct petitioners to file the required petition package with the designated Albany office in person or by mail; a local hearing location does not create a local filing office.
City Assessment Review
For City of Rochester assessments, original Form RP-524 submissions must reach the Bureau of Assessment by 8 p.m. .n the third Tuesday in March. The city does not accept the form by email or fax, and a timely postmark alone is insufficient.
The Board of Assessment Review, or BAR, provides formal administrative review. An informal conversation with assessment staff does not replace the BAR complaint needed to preserve further review rights.
After BAR review, eligible owners may seek Small Claims Assessment Review through the Monroe County Clerk. Others may pursue an RPTL Article 7 proceeding in Supreme Court, subject to applicable requirements.
For property assessment review, verify eligibility and the deadline tied to final assessment-roll filing or notice. Do not rely solely on a recurring calendar date.
4. Frequently Asked Questions
Related tax issues may share documents without sharing a filing procedure. Location also matters when identifying the office responsible for a property assessment.
Yes, returns and transaction records may support both reviews. Each agency still requires a response addressing its own notice, disputed items, and deadline.
Not necessarily. Confirm the municipality where the property lies and the assessor listed on the assessment roll before using city forms or deadlines.
5. When a Tax Notice Calls for Legal Review
Legal review can clarify the next step when a notice raises personal liability, overlapping proceedings, or an approaching petition deadline. Bring the complete notices, relevant returns, supporting records, and proof of prior submissions so an attorney can assess the procedure and unresolved issues.
20 Oct, 2026
