Legal aid and clients urge changes to DOR offer-and-settlement process, say $5,000 threshold and opaque denials trap taxpayers

Joint Committee on Revenue · November 7, 2025

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Summary

Attorneys from Greater Boston Legal Services and community clinics told the Revenue Committee that Massachusetts’ Department of Revenue offers-and-settlement process is effectively inaccessible for low‑income taxpayers, citing a reported $5,000 practical minimum, subjective denials, lack of written standards and limited appeals.

Attorneys from Greater Boston Legal Services and client witnesses told the Joint Committee on Revenue that the state’s offer‑and‑settlement process leaves many low‑income and vulnerable taxpayers with no realistic path to resolve tax liabilities. Laura Brown, a tax attorney with three decades of experience, said the Department of Revenue’s practice is “the wild west” with subjective requirements, repeated document requests and denials that lack written standards.

Brown and other advocates told the committee that the department’s practice effectively requires a $5,000 deposit for many offers, a barrier for low‑income taxpayers: “The $5,000 cover charge you have to file an offer in compromise. You can't do that,” Brown said during testimony. Clinicians and legal clinics said clients often lack the funds to meet that de‑facto threshold and then face enforced collection actions, including suspension of driver’s licenses, professional licenses and registration, which can prevent people from working.

Several clients testified to personal hardship scenarios the advocates described: Dale Weaver said he fell behind after family and medical crises and described being unable to secure an agreement after paperwork problems; Ross Rosano and Richard Torsney described long histories of addiction, family medical crises, business losses and other shocks that left them unable to pay taxes and reliant on legal clinics to seek resolution. Advocates said DOR accepted only four offers in 2024 and that there is limited transparency and no formal appellate path for denied offers.

Witnesses asked the committee to enact S.2027 to (1) require clearer standards and regulations for offers and settlements, (2) allow smaller initial deposits and accept smaller offers for qualifying taxpayers, and (3) create an internal appeal or review mechanism and greater transparency in denials. Advocates said the federal IRS offer‑in‑compromise model provided precedent for a workable settlement process and that a state program could yield revenue while returning taxpayers to compliance.

What’s next: Witnesses provided written testimony and asked the committee to consider changes that would allow DOR to resolve more cases administratively and reduce long‑term collection burdens on vulnerable taxpayers. No committee vote was recorded at the hearing.

Sources and provenance: Testimony by Laura Brown (transcript block 73), client testimony from Dale Weaver (blocks 87–96), Ross Rosano (blocks 141–160) and Richard Torsney (blocks 167–185), and statements by Mark Cotton of the Asian American Civic Association (block 204) underpin the account.