Committee hears bill to clarify deadlines for tax appeals to state board

Senate Local Government heard testimony on Senate Bill 328 during a Friday committee hearing. The bill, introduced by Sen. Daniel Zolnikov, would change how the deadline is calculated for appeals from County Tax Appeal Boards to the Montana Tax Appeal Board (MTAB).

Travis Brown, chairman of the Montana Tax Appeal Board, told the committee the current rule—30 days from the day a taxpayer "receives" the county board decision—creates uncertainty because counties have differing mailing practices and taxpayers sometimes are not at the mailed address. "This is kinda more a pro taxpayer bill," Brown said, adding that CTABs typically mail a decision within about three days of the hearing. Under the bill, a taxpayer could appeal to MTAB either within 45 days after the county tax appeal board decision or within 30 days after the county mails the decision to the taxpayer, which Brown said provides a definite start and end to the appeal timeline.

Danielle Pease, an attorney with the Department of Revenue, was listed as an informational witness. Committee members asked whether the change could cause taxpayers to miss the right to appeal; Brown replied the change effectively extends the deadline by roughly 15 days to account for mailing delays and that MTAB uses whatever address the filer provides when filing with the board.

Senator Beard asked whether county decisions are mailed by certified mail; Brown replied counties do not generally use certified mail for CTAB decisions. No opponents appeared and the committee closed the hearing without taking action.

The bill's sponsors and MTAB characterized SB 328 as intended to reduce administrative ambiguity and protect taxpayers' appeal rights. The committee did not vote; next steps will follow the committee's scheduling calendar.