To file a Pennsylvania tax appeal, you submit Form REV-65 to the Department of Revenue’s Board of Appeals within the deadline printed on your assessment notice, then, if you lose, petition the Board of Finance and Revenue, and finally, if needed, ask Commonwealth Court to review. Every stage has a firm deadline measured from the mailing date on the notice or decision you received, and missing one almost always ends your right to challenge the tax.
The Three Stages, In Order
Pennsylvania uses a two-tier administrative process followed by judicial review. The Board of Appeals sits inside the Department of Revenue and takes the first look at assessments, refund requests, denials of property tax and rent rebate claims, and denials of charitable exemptions.1Department of Revenue. Tax Appeals If that decision goes against you, the Board of Finance and Revenue (BF&R), an independent body under the State Treasury, reviews the matter with fresh eyes.2Pennsylvania Treasury. Board of Finance and Revenue Only after the BF&R issues a final decision, or fails to decide within its statutory window, can you take the case to Commonwealth Court. You cannot skip a step.
Deadlines at Every Stage
Every clock starts on the mailing date printed on the notice or decision. Not the day you opened the envelope. Not the day you read it.
Filing With the Board of Appeals
For personal income tax assessments, you have 90 days from the mailing date of the assessment notice to file. An extension of up to 30 additional days may be granted for good cause.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board The 90-day window took effect January 27, 2025, under Act 123 of 2024, replacing a previous 60-day deadline.2Pennsylvania Treasury. Board of Finance and Revenue For other tax types, including sales and use tax and corporate taxes, the filing window is generally 60 days. Because the timeframe depends on the tax type, check the specific deadline printed on your notice or on Form REV-1799A.4Pennsylvania Department of Revenue. REV-1799A – Time Limitations on Filing Petitions for Appeal
Appealing to the Board of Finance and Revenue
After the Board of Appeals rules, you have 90 days to petition the BF&R for personal income tax, employer withholding tax, and pass-through entity assessments. For most other tax types the deadline is 60 days. A 30-day extension may be available for cause.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board
Appealing to Commonwealth Court
Once the BF&R mails its decision, you have 30 days to file a petition for review with Commonwealth Court. The same 30-day clock starts if the BF&R fails to decide within its six-month window.5Legal Information Institute. 61 Pa Code 119.8 – Appeal to a Commonwealth Court
Preparing the Board of Appeals Petition
Your appeal begins with Form REV-65, the Board of Appeals Petition Form, available from the Department’s website and through the Online Petition Center.6Pennsylvania Department of Revenue. Board of Appeals Petition Form REV-65 There is no filing fee.
Pull these details from your assessment notice before you start:
- Assessment Letter ID
- Account ID
- Assessment Letter Mail Date, which sets your filing deadline
- Tax period begin and end dates, in MM/DD/YYYY format
The heart of the petition is the “Issues & Arguments” section. Explain precisely why the Department’s assessment is wrong. Point to specific errors in calculation or legal reasoning, and cite the relevant tax code sections or prior rulings where you can. General disagreement with the amount, or with tax policy, will not carry the petition.6Pennsylvania Department of Revenue. Board of Appeals Petition Form REV-65
You must sign an affidavit, under penalty of perjury, stating that the facts are true and that the petition is not filed for delay.7Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9703 – Petition Procedure
Documents to Attach
Attach whatever backs up your arguments: receipts, invoices, financial statements, contracts, bank records. For corporate appeals, board minutes or agreements showing the nature of specific transactions can be decisive. Label each document and reference it in your written arguments so the hearing officer can follow the trail.
For a refund petition, include proof you paid the tax. Canceled checks or bank statements showing payment to the Commonwealth are the standard evidence.8Pennsylvania Treasury. Board of Finance and Revenue Petition Form
Where to Send It
You can file electronically through the Board of Appeals Online Petition Center, which gives you instant confirmation of receipt.9Pennsylvania Department of Revenue. Board of Appeals Online Petition Center Paper petitions go to: PA Department of Revenue, Board of Appeals, PO Box 281021, Harrisburg, PA 17128-1021. The Board does not accept petitions by email or fax.1Department of Revenue. Tax Appeals If you mail your petition, use certified mail with a return receipt. A petition is timely if it is postmarked on or before the deadline, so keep that postmark.
What Happens After You File
The Board assigns a docket number and, if you requested a hearing, schedules one in person or by telephone. A hearing lets you walk the officer through your evidence and answer questions directly.
The Board has six months from the date it receives your petition to issue a written decision.7Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9703 – Petition Procedure If it does not decide within that window, you can treat the inaction as a denial and move to the BF&R.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board
One thing that catches people off guard: interest generally keeps accruing on unpaid tax while your appeal is pending. Filing does not freeze the meter. If you lose, you owe the original tax plus all the interest that piled up during the appeal. That’s worth weighing when you decide whether to pay the disputed amount now and fight for a refund, versus withholding payment while you contest.
Petitioning the Board of Finance and Revenue
If the Board of Appeals denies your petition, or you treat its inaction as denial, you file a petition for review with the BF&R. The board uses its own online portal, the BF&R Tax Appeal Portal, to receive electronic filings. If you cannot use the portal, mail the petition or email bfr@patreasury.gov for instructions.2Pennsylvania Treasury. Board of Finance and Revenue
The petition must state the tax type, the tax periods, the amount you believe was wrongly assessed or overpaid, and the basis for your claim. You can meet the “basis” requirement by incorporating your Board of Appeals arguments by reference; you don’t have to rewrite them.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board Include an affidavit and a valid mailing address (optionally an email) for future correspondence.
The BF&R has six months to decide, with one possible six-month extension at either party’s request.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board If it does not act, the petition is deemed denied by operation of law and your 30-day Commonwealth Court clock starts.10Pennsylvania Code and Bulletin. 61 Pa Code Chapter 703 – Tax and Other Appeal Proceedings
Settlement Conferences at the BF&R
Act 123 of 2024 created a settlement conference option at the BF&R for petitions filed on or after January 27, 2025. Either party can request one within 30 days of filing the BF&R appeal, and the board can also direct one on its own. If approved, the BF&R pauses its review while the parties try to settle.2Pennsylvania Treasury. Board of Finance and Revenue
Conferences are run by independent settlement officers who must be attorneys or CPAs with tax experience, and who are independent of both the Department of Revenue and the Treasury. They cannot force a deal, but they can hold private conversations with each side and make recommendations. The conference must occur within 60 days of the BF&R deferring the case. Any agreement must be approved by the BF&R, and once approved it cannot be appealed and does not set a precedent for other cases. The Department of Revenue must attend if a conference is scheduled; you as the taxpayer can decline.
Commonwealth Court
Court review only opens after both administrative stages. File a petition for review within 30 days of the mailing date of the BF&R’s decision, or within 30 days of the end of the six-month decision window if the BF&R failed to act.5Legal Information Institute. 61 Pa Code 119.8 – Appeal to a Commonwealth Court Both the taxpayer and the Commonwealth can appeal an unfavorable BF&R decision.
Court proceedings are substantially more complex and expensive than the administrative stages. You’ll follow Commonwealth Court procedural rules, and the court reviews the record built at the administrative level. For most taxpayers the practical question is whether the amount at stake justifies the cost of litigation.
Representing Yourself or Hiring Help
You can represent yourself at every stage. Nothing requires you to hire an attorney, accountant, or other professional.1Department of Revenue. Tax Appeals If you use a representative, they must have the relevant technical knowledge and be authorized in writing to act for you.
At the BF&R, appearances can be made by the taxpayer or by an attorney, accountant, or other representative, so long as the work does not cross into the unauthorized practice of law.3Pennsylvania General Assembly. Pennsylvania Code Title 72 PS Taxation and Fiscal Affairs 9704 – Review by Board In practice, a CPA or enrolled agent can handle most tax appeal matters, but complex statutory interpretation arguments may require an attorney. At Commonwealth Court, procedural complexity makes professional representation a near-necessity for most taxpayers.
If You Win: Federal Tax to Watch
Winning a state tax appeal and getting a refund can create a federal income tax obligation. If you itemized deductions on your federal return and deducted the Pennsylvania taxes you paid, a refund of those taxes may be partially or fully taxable as federal income in the year you receive it. If you took the standard deduction in the year you paid the tax, the refund is not federally taxable.11Internal Revenue Service. 1099 Information Returns – All Other The IRS “Recoveries of Itemized Deductions” worksheet in Publication 525 walks through how much of a refund is taxable. If your appeal results in a substantial refund, run it through with your tax preparer before filing your next federal return.