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The audit ran, and now there is a number: additional tax, penalty, and interest, often built from a sample projected across years. That number is a proposed assessment, not a final bill. You have a limited window to contest it — and missing that window turns a disputable assessment into a collectible debt.
Miss whichever one applies and the assessment is final. Protecting the deadline is the first thing a defense does — before any argument about the sample.
The petition window varies by state. California gives 30 days to petition for redetermination. New York allows 90 days to petition the Division of Tax Appeals. Miss whichever one applies and the assessment is final. Audit defense is the work of contesting that number on the merits AND protecting that deadline.
The leverage is technical: an assessment is only as strong as the sample and method behind it. Arguing that it is unfair does not move the number. Showing the sample was unrepresentative or the projection overreached — with records behind it — does.
Four technical challenges + one procedural protection. Each with records behind it.
We pull the auditor's workpapers and see how the sample was chosen and how the projection was built. That's where the leverage lives — a proposed assessment is only as strong as the method behind it.
Challenge the sample when the period or transactions used were not representative of normal operations. Contest the projection when applying the sample rate across the full period overstates the result. Both are recoverable.
Dispute penalties that do not fit the facts — including negligence findings piled on top of the base tax. Penalty removal alone often changes the number materially.
File the petition for redetermination in time and carry the appeal through the state's process, negotiating the assessment down where the case supports it.
We pull how the auditor reached the number and pin the date the petition is due — because that date governs everything. The strongest case is worth nothing filed late.
We test the sample, the projection, and the penalties against the records and the law, and assemble the evidence that the number is wrong. Every argument tied to something documentary.
We file the petition in time and carry the appeal, negotiating the assessment down where the case supports it. Some matters resolve at the petition stage. Some go further.
Why Businesses Trust Dimov Tax
An assessment comes down when you show the sample was unrepresentative, the projection overreached, or the penalty does not fit. That takes CPA-level technical review, not appeals paperwork alone.
Cost depends on the size of the assessment, how the sample and projection were built, the number of issues contested, and whether the matter resolves at the petition stage or goes further in the appeals process. We size it after reviewing the assessment and the auditor's workpapers.
You do not need to know what is wrong with the assessment before you call. Finding that in the workpapers is the work. What matters now is moving before the deadline does.
Every state has a fixed window to petition a proposed sales tax assessment. Miss it and the number is final — even if the sample was flawed, even if the projection was wrong, even if the penalty didn't fit the facts. Late = collectible debt.
The strongest merits argument is worth nothing filed after the deadline. Protecting the date is the first thing a defense does — before any argument about the sample.
Sources: CDTFA Publication 17, Appeals Procedures; New York Division of Tax Appeals FAQ
Act if:
Every one of these comes down to one date. Miss it and the number is final; act while it is open and everything stays contestable. Earlier in the audit? See sales tax audit. Want to prevent the next one? See sales tax compliance services.
Tell us your notice date and we will tell you what can be contested and protect your petition window. You can share the assessment and workpapers at the next step.
This page provides general information about contesting a sales tax assessment and does not constitute tax, legal, or financial advice. Any result depends on the specific facts, the records available, the assessment itself, and each state's process, so no particular reduction or outcome can be guaranteed. Petition and appeal deadlines are strict and vary by state; consult a qualified Dimov Tax professional about your own notice before the window closes.
Share the notice at the next step. Confidential, no obligation.
