Connecticut General Statutes

Conn. Gen. Stat. § 12-521 (2026)

Appeal to commissioner

✓ current as of May 2026

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Any person, aggrieved by the action of the commissioner or his authorized agent in fixing the amount of any tax, penalty or interest provided for by this chapter may apply to the commissioner, in writing, within sixty days after notice of such action is delivered or mailed to him, for a hearing and a correction of the amount of the tax, penalty or interest so fixed, setting forth the reasons why such hearing should be granted and the amount in which such tax, penalty or interest should be reduced. The commissioner shall promptly consider each such application and may grant or deny the hearing requested. If the hearing is denied, the applicant shall be notified thereof forthwith. If it is granted, the commissioner shall notify the applicant of the time and place fixed for such hearing. After such hearing the commissioner may make such order in the premises as appears to him just and lawful and shall furnish a copy of such order to the applicant. The commissioner may, by notice in writing, at any time within three years after the date when any return of any person has been due, order a hearing on his own initiative and require the person filing such return or any other individual whom he believes to be in possession of relevant information concerning the taxpayer or the person filing such return to appear before him or his authorized agent with any specified books of account, papers or other documents, for examination under oath.

(June, 1969, P.A. 1, S. 42; June, 1971, P.A. 8, S. 19; P.A. 91-236, S. 13, 25.)

History: 1971 act substituted “person” or “person filing such return” for “taxpayer” in most references and added “person filing such return” in provision re appearance of persons with relevant information before commissioner; P.A. 91-236 provided for 60, rather than 30, days to request a hearing, effective July 1, 1991, and applicable to taxes due on or after that date.

Cited. 163 C. 478; 185 C. 186.

No interest is to be paid on a refund made administratively by the tax commissioner of an overpayment of the capital gains and dividends tax. 31 CS 134.

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Notes of Decisions

Cited in 4 cases, 1972–2011 · leading case: Housatonic R.R. v. Comm'r of Revenue Servs., 21 A.3d 759 (Conn. 2011).

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Housatonic R.R. v. Comm'r of Revenue Servs., 21 A.3d 759 (Conn. 2011). · cites it 4× “siness tax); General Statutes § 12-268l (appeals regarding railroad company, community antenna television system, public utility company and public service company taxes); General Statutes § 12-422 (appeals regarding sales and use taxes); General Statutes § 12-448 (appeals…”

Woodruff v. Tax Comm'r, 440 A.2d 854 (Conn. 1981). · cites it 4× “On July 28, 1976, plaintiffs, by their counsel and pursuant to Conn. Gen. Stat. § 12-521 , requested a hearing before the State Tax Commissioner to determine the proper Capital Gains and Dividends Tax due.”

Kellems v. Brown, 313 A.2d 53 (Conn. 1972). “Section 12-522 provides for an appeal to the Superior Court by any person aggrieved because of any order, decision, determination or disallowance of the tax commissioner. There is no suggestion in the plaintiffs’ complaint or in the stipulation of facts that any of the…”

Marsh v. Brown, 325 A.2d 466 (Conn. Super. Ct. 1974). · cites it 6× “” The plaintiffs then requested a hearing on their interest claim, pursuant to General Statutes § 12-521. On July 2, 1973, the commissioner denied the request for a hearing, advising that “in the absence of a statutory provision for the payment of interest and lack of directive…”

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