Baltimore

In Baltimore, a tax notice can come from the IRS or from the Comptroller of Maryland, which also collects the city's income tax. Either way, start by finding out what the notice means and when you must answer. Michael March, a Baltimore tax attorney, answers those questions from Whiteford's headquarters at 7 St Paul Street. The office serves people and businesses in the city and the counties around it.

Michael represents individuals, closely held businesses, estates and nonprofits in IRS audits, collection cases, appeals and criminal tax investigations. The same team handles assessments from the Comptroller of Maryland.

Look at the date printed on the notice. Your deadline usually counts from it, not from the day you opened the envelope. We check that date first, whether the letter is an IRS audit notice, a Maryland notice of assessment or something else.

Baltimore tax problems and where they start

Many Baltimore tax problems grow out of how people here earn a living and where they live. These are some common patterns, each with a page that goes deeper.

Hospitals, universities and charities. Being tax-exempt generally does not excuse an employer from payroll taxes. When withheld taxes go unpaid, the people responsible for paying them can owe that money personally. Our page on tax disputes for nonprofits explains the risks.

Doctors, researchers and executives. Pay at the hospitals, universities and downtown firms can arrive as salary, consulting fees, stock awards or deferred compensation. Some of it is taxed in a year that does not match the cash, as our page for professionals and executives explains.

Landlords and owners of historic buildings. The IRS looks closely at rental losses and at facade easement deductions on historic properties. See real estate tax disputes and IRS audits in Baltimore.

Households that owe more than they can pay. The IRS allows less for housing in Baltimore City than in the counties around it. That can raise the smallest offer in compromise the IRS will generally accept from a city household.

City residents. Baltimore City taxes its residents' income at 3.20% for 2026. The Comptroller of Maryland collects it with the state tax, on the same return. So a dispute over it follows the Comptroller's steps below. If the IRS raises your federal income, the city tax can rise too. You then have 90 days from the IRS's final determination to report the change to the Comptroller, under Tax-General § 13-409.

Steps and deadlines in a Comptroller of Maryland appeal

A Comptroller of Maryland assessment works differently from an IRS notice of deficiency. Three of its deadlines are 30 days, and missing the first one can cost you the appeal.

The appeal, step by step

1. Apply for revision. File an application for revision within 30 days after the Comptroller mails the notice of assessment, under Tax-General § 13-508(a). If you miss that window, the assessment becomes final under § 13-508(b).
2. Go to the informal hearing. The Comptroller or a designated employee hears your side, then mails a notice of final determination under § 13-508(c). You must finish this step before the Maryland Tax Court can hear you, under § 13-514.
3. Appeal to the Maryland Tax Court. You have 30 days after the notice of final determination is mailed, under § 13-510(a). A petition mailed with a postmark inside that window is on time, under § 13-510(c).
4. Build the record there. The Maryland Tax Court hears the whole case over again, much like a trial without a jury, under § 13-523. Later courts review the record made there, so your evidence should go in at this stage.
5. Seek review in circuit court. You usually have 30 days to file the petition (Maryland Rule 7-203). A city taxpayer can file it in the Circuit Court for Baltimore City, under State Government § 10-222. A further appeal goes to the Appellate Court of Maryland under State Government § 10-223. That court also looks at the Maryland Tax Court's decision, not the circuit court's.

Time limits to assess and collect

The Comptroller generally has three years to assess more income tax, under § 13-1101(a). The three years run from the later of the day you filed and the day the return was due. No time limit applies if no return was filed, the return was incomplete, or a false return was filed to evade the tax, under § 13-1101(b).

Sales and use tax has a four-year limit from the due date, under § 13-1102(a). That limit disappears for fraud or gross negligence, under § 13-1102(b). A shortfall of 25% or more is prima facie evidence of gross negligence, meaning it counts as proof unless you show otherwise, under § 13-1102(b)(1)(ii).

Maryland can generally collect a tax for ten years, under § 13-1103(a). A Maryland tax lien can last twice as long, as the lien question below explains.

The choice between the U.S. Tax Court and a refund suit

An IRS deficiency dispute can reach court in two ways. One is a petition to the U.S. Tax Court, filed before you pay. The other is a refund suit, which comes after you pay. It can be filed in the District of Maryland or in the Court of Federal Claims.

Which route fits depends on the amount at issue, your cash, the strength of your records and which court's past rulings favor you. It is worth deciding on purpose rather than by default. Our page on tax litigation in Baltimore walks through both routes.

The firm behind a Baltimore matter

Whiteford, Taylor & Preston LLP has been headquartered in Baltimore since 1933. Its more than 200 attorneys work from 19 offices in the District of Columbia and ten states. So if a tax matter turns into a bankruptcy question, a shareholder dispute or a criminal referral, the lawyer you need is already in the firm.

Michael March leads the tax controversy practice from this office and co-chairs the firm's tax section. His work covers federal criminal tax matters in the U.S. District Court for the District of Maryland, deficiency cases in the U.S. Tax Court, and Maryland state disputes. The firm's tax lawyers also appear before the Maryland Tax Court on state assessments. They work alongside the firm's state and local tax, white collar defense and estates groups.

Meet Michael

Michael March

Partner, Co-Chair Tax Section

View Michael's profile →