DRS: Filing An Appeal

Filing a Protest

If you disagree with a notice of assessment, notice of proposed disallowance of a claim for refund, or other determination or decision by the Commissioner, you may file a written protest with our Appellate Division. The Appellate Division will work with you to resolve any outstanding issues, but it cannot disregard Connecticut tax laws in order to settle a dispute.


As set forth above, state law requires that your protest be in writing.  For your convenience, an optional Form APL-002, Appellate Division Protest Form, is available for you to complete and file your protest.  Fax your protest and all supporting documentation to 860-297-4780 or by using the United States mail send the protest and documentation to:


Department of Revenue Services
Appellate Division
25 Sigourney Street Ste 2
Hartford CT 06106-5032

A protest of a notice of assessment or notice of proposed disallowance of a claim for refund, must be received within 60 days or must bear a United States postmark that is within 60 days after the date of the notice of assessment, notice of proposed disallowance, or other determination or decision by the Commissioner.

A protest of a jeopardy assessment must be received within ten days or must bear a United States postmark that is within 10 days after the date of the notice of assessment.

See Mailing or Delivering Returns, Protests or Other Documents, or Payments to DRS.

Additional Information: 

  • If you are protesting a notice of assessment and have not paid the assessment, interest will continue to accrue on the tax assessed while your protest is being considered by our Appellate Division. To minimize the accrual of interest, see APL-004 , Deposit in the Nature of a Cash Bond.
  • Use LGL-001, Power of Attorney , to authorize one or more individuals to represent you before the DRS. This authorization allows your representative(s) to receive and inspect confidential tax information and to act on your behalf in matters before DRS.  Connecticut law stipulates that all official mailings will be sent to the taxpayer of record at the address on file with DRS. This power of attorney does not change the requirement that DRS send all official mailings directly to the taxpayer.  However, if a Form LGL-001 is on file in connection with the protest, the Appellate Division will send a copy of all notices to the representative.
  • If you do not dispute the assessment, but do not believe you have the financial ability to pay the assessment, you can file an Offer of Compromise with the Departmentís Collection and Enforcement Division.  Please refer to IP 2004(31), Procedures for Making Offers of Compromise .

Regardless of whether you use Form APL-002 or submit a separate written protest, any written protest should clearly state all of the following:

  • Your name and address;
  • Your Connecticut Tax Registration Number or Social Security Number;
  • Case Identification Number;
  • Tax type;
  • Taxable period or periods;
  • A statement that you are protesting the notice of assessment or proposed disallowance; and
  • A factual statement for each disputed issue that supports your position and a statement of the law or other authority on which you rely.

When the Appellate Division receives your protest, you will be sent a letter acknowledging its receipt. Your protest will be assigned to an appellate officer (or appellate specialist). You will have the opportunity to provide the appellate officer with any information you believe will help resolve your protest. It would be helpful if this information is provided with your completed APL-002 (or other form of written protest).  The appellate officer will consider all relevant information, in most cases, contact you (or your designated representative) and will send you a letter containing the Appellate Divisionís final determination.

If you disagree with the final determination letter, you may take an protest to the Superior Court for the Judicial District of New Britain within one month from the date of the final determination letter.

If you have questions about filing an protest or the protest process, call 860-297-4775, Monday through Friday, during business hours. Also see Policy Statement 2008(4), Your Rights as a Connecticut Taxpayer, for additional information.