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Maryland

Towson

Baltimore County tax disputes with the IRS or the Comptroller of Maryland, handled from Towson Commons near the county courthouse.

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If a tax notice has reached your home or business in Baltimore County, a Towson tax attorney at Whiteford can help you answer it. It may come from the IRS, from the Comptroller of Maryland, or from the state's property assessors. Each has its own clock and its own path to court, so the sender shapes almost every step that follows.

Working out who sent your tax notice, and which deadline its date starts, is our job. You do not need to settle that before you call. Tax letters are dense and their deadlines strict. So the first conversation is about taking the rush out of your reply. We look at what the notice claims, how much time is left, and which records will answer it.

Michael March leads the firm's tax controversy practice. He takes a case from the first audit letter through the Tax Court and, if criminal exposure appears, through a federal investigation.

Get directions Towson Commons, Suite 300, One West Pennsylvania Avenue By appointment only. to the Towson office (opens Google Maps in a new tab)

Common matters we see here

Local regulators & venues

Circuit Court for Baltimore County

The court sits on Bosley Avenue in Towson, the county seat, a short walk from our office. Maryland's rules for court review of agency decisions decide where the petition goes. It is filed in the county where a party resides or has a principal place of business. So for a Baltimore County taxpayer, this is usually the court that reviews a Maryland Tax Court decision.

State Department of Assessments and Taxation

SDAT, as the department is called, values real property through its Baltimore County Assessment Office. That office is at Hampton Plaza, 300 East Joppa Road in Towson. SDAT also assesses business personal property. Appeals run from SDAT to the Baltimore County Property Tax Assessment Appeals Board, then to the Maryland Tax Court, then to circuit court. The county's Office of Budget and Finance, on Washington Avenue, bills and collects but does not set values.

Comptroller of Maryland

The Comptroller assesses and collects Maryland income tax, sales and use tax, and the Baltimore County income tax. The county sets its rate by ordinance, within a range set by state law: currently at least 2.25% and at most 3.30% of Maryland taxable income. The county tax is reported on the same return as the state tax. So a dispute over it is a dispute with the Comptroller, not with the county.

Maryland Tax Court

Based in Baltimore City, it is an independent administrative unit of state government, not a court in the judicial branch. Appeals reach it from the Comptroller and from the Property Tax Assessment Appeals Board. From there a case goes to circuit court, which reviews the record rather than retrying the facts, and then to the Appellate Court of Maryland.

U.S. Tax Court

Maryland trial sessions are scheduled in Baltimore. With your petition, you file a separate Request for Place of Trial naming the city you prefer. The court then sets the session and notifies both sides, and a later motion can change the city. A deficiency case can come here before you pay the tax.

U.S. District Court for the District of Maryland

Cases from Baltimore County are heard at its Baltimore courthouse. To sue here for a refund, you must first pay the assessed tax in full. That is often why a case goes to the Tax Court instead. An important exception is a divisible tax, such as an employment tax or a trust fund recovery penalty. For those, you generally need to pay only the amount tied to one employee for one quarter before suing. The government then counterclaims for the rest.

When the notice is from Maryland

A missed deadline can end a case before anyone looks at the facts. Each window below runs from the date printed on the notice or order, not the day it reached you.

  • Comptroller notice of assessment: 30 days to file an application for revision, under Maryland Code, Tax-General § 13-508(a).
  • Comptroller notice of final determination: 30 days to petition the Maryland Tax Court, under Tax-Gen. § 13-510(a).
  • SDAT notice of assessment for real property or business personal property: 45 days to appeal the value.
  • SDAT's final notice after that appeal: 30 days to take the case to the Property Tax Assessment Appeals Board.
  • Maryland Tax Court order in a Baltimore County case: generally 30 days to petition the Circuit Court for Baltimore County.

If you miss the revision deadline, the assessment becomes final and that route closes. You can still pay, file a refund claim and, if it is denied, petition the Maryland Tax Court under § 13-510(a)(6). That remedy is narrower and slower, but it is still a remedy.

A petition to the Maryland Tax Court is on time if it is postmarked inside the window, under § 13-510(c). But under § 13-514, you must first exhaust all available administrative remedies, meaning every step of review the agency offers.

When the notice is from the IRS

IRS deadlines also run from the date on the notice.

If you miss the 30 days on a levy notice, you can still ask for an equivalent hearing within one year. But an equivalent hearing generally carries no right to Tax Court review.

A notice of deficiency addressed to you outside the United States gives you 150 days instead of 90. Either way, the Tax Court treats the deadline as jurisdictional and will not extend it. It applies that rule in Maryland cases. The Second, Third, Sixth, and Eighth Circuits have since held otherwise. They call it an ordinary claim-processing rule, which can be equitably tolled in narrow cases. The Fourth Circuit, which would hear a Maryland taxpayer's appeal, has not decided the question.

No one should plan around tolling. Still, if your date has passed, that unsettled law is a reason to call before you assume the case is over.

If the IRS has added a penalty, our page on penalty abatement explains how to ask to have it removed.

Experience behind a Towson file

Michael March is admitted before the U.S. Tax Court and before the U.S. District Court for the District of Maryland, which hears federal cases from Baltimore County. He is also admitted to the U.S. Court of Federal Claims and the U.S. Court of International Trade.

Michael has represented people against the Department of Justice in the federal district courts of Maryland, the District of Columbia, Virginia, West Virginia, Delaware, and Florida. Those cases involved alleged bank fraud, failures to report foreign bank accounts, and tax evasion. Michael has also taken civil disputes through every stage at the IRS and into the Tax Court. In those matters, the IRS, the FBI, and the Department of Homeland Security were investigating at the same time.

The firm has practiced in Maryland since 1933. It keeps offices in Towson, Baltimore, and Columbia, with more than 200 attorneys across 19 offices in ten states and the District of Columbia.

For a Towson matter, the attorney who reads your file also writes the response and appears at the hearing. If the case develops criminal exposure, it can move to a white collar defense bench within the same firm.

What we handle

IRS Audits

What an IRS audit involves, why the IRS opens one, and how an attorney protects your position from the first letter.

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IRS Collections

What the IRS can do to collect a tax debt, the rights that apply at each step, and the ways to stop enforcement.

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Tax Debt Relief

Offers in compromise, installment agreements, injured spouse relief, and other options for how to settle IRS debt and stop enforcement: what each one does, who qualifies, and what to expect.

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White Collar Tax Defense

When the IRS treats a tax problem as a crime, what conduct is charged, and how a defense attorney answers it.

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Why taxpayers choose Whiteford

  • Maryland practice since 1933, with offices in Towson, Baltimore, and Columbia.
  • Free initial consultations, in Towson or by video, to find out whether our attorneys can help resolve your tax matter.
  • A matter that develops criminal exposure transfers to a white collar bench within the same firm.

Frequently Asked Questions

Where is the Towson office, and where do I park?
Towson Commons, Suite 300, One West Pennsylvania Avenue, Towson, MD 21204-5025. The building has an on-site parking garage. Visitors cross the breezeway to the elevator lobby, sign in at the first-floor security desk, and go up to the third floor. The Circuit Court for Baltimore County is a short walk away.
Do I have to come to Towson?
No. Most of the work in a tax dispute is letters, documents, and calls with a revenue agent, a revenue officer, or a Comptroller hearing officer. We handle Baltimore County matters by phone and video and save in-person time for meetings that benefit from it. Whiteford also has offices in Baltimore, Columbia, and Washington, DC.
What should I bring to a first meeting?
Bring every notice you have received, with the envelopes if you still have them. Also bring the returns for the years in question and any letters you have already sent. If IRS Criminal Investigation or a Comptroller field agent has contacted you, tell us when you call, not at the meeting. That changes how the first conversation goes.
If the Maryland Tax Court rules against me, where does a Baltimore County case go next?
Usually to the Circuit Court for Baltimore County, on Bosley Avenue in Towson. Under Tax-Gen. § 13-532, any party, the Comptroller included, may seek circuit court review of a final Tax Court order. The petition is generally due within 30 days of the order. The circuit court looks only at the Tax Court record, so your evidence must be in before the Tax Court rules. Filing does not pause the order, which stays enforceable unless the circuit court grants a stay.
Can you help with a Baltimore County property tax assessment?
Yes. The state's assessment office for Baltimore County, on East Joppa Road, values property in Towson. An appeal goes from that office to the Baltimore County Property Tax Assessment Appeals Board, then to the Maryland Tax Court. After that comes circuit court, which looks only at the record. Businesses that file annual personal property returns answer to the same state agency.
My notice came from the Comptroller of Maryland, not the IRS. Is the process the same?
No. A Maryland assessment has its own steps and its own clock. You have 30 days from the notice of assessment to file an application for revision. An informal hearing follows, before the Comptroller or a designated employee. Then you have 30 days from the notice of final determination to petition the Maryland Tax Court.
The IRS and the Comptroller are both reviewing the same year. Does one result bind the other?
Not automatically. Maryland income tax follows federal taxable income. Under Tax-Gen. § 13-409, you must report an IRS adjustment within 90 days after the IRS's final determination. But the Comptroller can use its own figure where the federal one is wrong. You can also contest the federal result in the Maryland case. A federal closing agreement under IRC § 7121 is the exception: it binds as the basis for Maryland income tax. A position in one can create risk in the other, so the two must be handled together.
Can I get a penalty on an IRS or Comptroller bill removed?
Sometimes. With three years of timely compliance, you can ask the IRS for first-time abatement of a failure-to-file, failure-to-pay, or failure-to-deposit penalty without showing reasonable cause. For many returns from tax year 2025 on, the IRS now applies similar relief automatically, before any penalty is assessed. Other IRS relief depends on reasonable cause. Removing an IRS penalty also removes the interest charged on it. A Maryland penalty needs its own request: under Tax-Gen. § 13-714, the Comptroller may waive it for reasonable cause.
Does requesting a Collection Due Process hearing stop a levy?
Generally, yes. A timely request stops levy on the taxes and periods in the notice. The stop lasts while the hearing and any Tax Court appeal are pending. There are narrow exceptions, such as a jeopardy levy or a levy on a state tax refund. The hearing can also take up a spousal defense, such as innocent spouse relief, or whether the levy is appropriate.
When should an accountant hand a matter to a lawyer?
When a revenue agent starts asking why rather than how much, when a special agent makes contact, or when the accountant prepared the returns now under examination. The federally authorized tax practitioner privilege in IRC § 7525 does not reach criminal matters. And a preparer who is also a fact witness cannot advise on their own work.

Meet Michael

Michael March
Michael March
Partner, Co-Chair Tax Section
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