Taxpayers appealed the Administrative Law Judge's (ALJ) denial of their application for reinstatement after the Department denied their appeal as untimely. The ALJ upheld the Department's denial, applying the new rule that became effective after Taxpayers received their Notice of Assessment, but prior to submitting the appeal the Department dismissed as untimely. The Director overturned the ALJ's ruling, finding that the ALJ applied the wrong rule and should have analyzed Taxpayer's appeal under the good cause standard in the previous rule.
2023-06-23