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Tax and Administrative Appeals Session

The Tax and Administrative Appeals Session of the Superior Court, which is located at the New Britain Superior Court, 20 Franklin Square, New Britain, is charged with two primary responsibilities. The first consists of state and municipal tax appeals. The second consists of appeals from state agencies under the Uniform Administrative Procedure Act (UAPA, General Statutes §§ 4-166 et seq.) We discuss these responsibilities below.

I. TAX APPEALS

The Tax and Administrative Appeals Session has exclusive statewide jurisdiction over appeals taken from 1) orders of the Department of Revenue Services, 2) certain decrees of the courts of probate, 3) orders of the Secretary of the Office of Policy and Management and 4) decisions of the Penalty Review Committee.

This jurisdiction covers the following areas:

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Insurance company taxes
Hospital taxes
Medical service corporation taxes
Corporate business tax
Gross earnings tax
Railroad company taxes
Public service company taxes
Cigarette tax
Tobacco products tax
Succession tax (appeals from probate)
Estate income tax
Sales and use tax
Alcoholic beverage tax
Motor vehicle fuel tax
Motor carrier tax
Dividends tax
Admissions, cabaret and dues tax
Petroleum products tax
Gross earnings tax
Income tax
Real estate conveyance tax

Appeals arising from challenges to municipal assessments of real and personal property are governed by General Statutes §§ 12‑117a and 12‑119 and must be filed with the Superior Court for the judicial district where the municipality is located. Therefore, the Tax and Administrative Appeals Session does not have statewide jurisdiction over these type of appeals.

Municipal property tax appeals filed in the New Britain judicial district as well as tax appeals filed in the Hartford judicial district (all of which are transferred to New Britain) are adjudicated to their final disposition in the New Britain judicial district. In all other judicial districts (Ansonia‑Milford, Danbury, Fairfield, Litchfield, Middlesex, New Haven, New London, Stamford‑Norwalk, Tolland, Waterbury, and Windham), the presiding judge may order municipal property tax appeals to be transferred to the Tax and Administrative Appeals Session for full disposition.

All municipal property tax appeals cases handled by the Tax and Administrative Appeals Session shall be subject to the Standing Order on Administrative Appeals under the UAPA and Tax Appeals (December, 2014), which is available through the link on the side of this page.

All tax trials in the Tax and Administrative Appeals Session are heard de novo before a Judge of the Superior Court or a Judge Trial Referee. There are no jury trials.

It is the mission of the Tax and Administrative Appeals Session to afford taxpayers a prompt and impartial hearing and disposition of their disputes with the Department of Revenue Services and local tax assessors.

The Tax and Administrative Appeals Session also strives to attain the following objectives: (1) provide to the taxpayer an expeditious, convenient, equitable and effective determination of his or her tax liability in a manner that is cost efficient for both the taxpayer and the state; (2) create a consistent, uniform body of tax law for the guidance of taxpayers, tax professionals and tax administrators, in order to promote predictable application of the tax laws; (3) make decisions of the Tax and Administrative Appeals Session readily available to taxpayers, tax professionals and tax administrators; and (4) promote the development of a qualified and informed state tax bar.

II. ADMINISTRATIVE APPEALS


Administrative appeals from state agencies encompass a wide variety of matters such as driver’s, medical, and other license suspensions, Freedom of Information Act cases, rate regulation by the Public Utility Regulatory Authority, and appeals from decisions of the State Board of Labor Relations, Commission on Human Rights and Opportunities, and Department of Children and Families. The Tax and Administrative Appeals Session has exclusive jurisdiction over these appeals with the exception of employment security review board cases. Therefore, even though it is permissible to file such an appeal in any judicial district, all such appeals filed in other districts will be transferred to New Britain and all cases will be heard there. The Session does not handle zoning and land use cases, which should be filed in the local judicial district.

The Uniform Administrative Procedure Act (UAPA, General Statutes §§ 4-166 et seq,) contains specific timetables and procedures for filing the appeal. Many of these rules relate to subject matter jurisdiction and thus will be strictly construed by the court.

Administrative appeals under the UAPA are appeals of record. Thus, the court does not conduct trials. Rather, the court, in effect, sits as an appellate court and reviews the record, considers the briefs of the parties, hears oral argument, and writes decisions. Every effort is made to move the cases along expeditiously.

This page contains a link to the standing orders of the Session. These standing orders pertain to transfer of administrative appeals to New Britain, motions to stay in driver’s license suspension cases, and certain other procedures for litigating tax and administrative appeals in the Session.

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