MN Commissioner’s Orders

Another client recently first became aware of a MN tax debt through a collection notice – the client never received the original Commissioner’s Order.  MN practice is to send out the Commissioner’s Order through ordinary first-class mail, not certified mail.  On the IRS side, the analogous Notice of Deficiency, or the Final Notice of Intent to Levy, are sent certified mail.

Given the importance of the Commissioner’s Order – failure to appeal within 60 days generally precludes the taxpayer from any pre-payment challenge – MN should send the Commissioner’s Order certified mail.  It would provide proof of receipt/non-receipt, and would also put the receiver on notice that something important has been sent.