A mistake on a Georgia tax return may start as a simple filing issue. However, the situation can become more serious when the Georgia Department of Revenue (DOR) changes a return or says that more tax is due. At that point, deadlines and formal dispute rules can turn a tax problem into a tax controversy.
What does the DOR notice mean?
The first step is to identify the type of notice. For example, the DOR may send a Notice of Return Changes after it changes information on a filed return. It may also send a Notice of Proposed Assessment after an audit or another review.
A proposed assessment explains the tax at issue, the filing period, the amount due and why the DOR believes the taxpayer owes it. A taxpayer who disagrees should not assume that calling the DOR will protect the right to challenge the amount.
Instead, Georgia allows taxpayers to follow a formal protest and appeal process. A taxpayer generally has 45 days from the issue date of a proposed assessment to file a protest. The protest should explain why the amount is wrong and include documents that support that position.
What happens if the dispute continues?
After receiving a protest, the DOR may ask for more information. If the taxpayer requested a conference, a department representative may also discuss the dispute with them. The DOR can then grant the protest, deny it or make adjustments.
If the taxpayer and the DOR cannot resolve the dispute, the DOR may formally assess the amount it believes the taxpayer owes. This step raises the stakes because the taxpayer generally has another 45 days to appeal.
Since July 1, 2026, taxpayers may bring certain state tax disputes before the Georgia Tax Court, which operates separately from the DOR. Depending on the case, a taxpayer may also appeal in the appropriate superior court.
Missing these deadlines can create larger problems. The DOR may eventually issue a state tax execution, also called a tax lien. Collection efforts may then affect wages, bank accounts or property.
How can early guidance help?
Tax controversies often involve more than correcting a number on a return. Records, deadlines and the reasons behind the DOR’s position can all shape the outcome.
An attorney can review the notice and explain the available options before an important deadline passes. Legal guidance may become especially useful when an assessment involves a large balance, a business tax issue or a possible appeal.