Under Minn.Stat. §270.56 subd. 3(b), with respect to personal liability orders from the Department of Revenue, if the original appeal date is missed, the taxpayer may be able to ‘get back into the game’ procedurally by making a partial payment within 3.5 years of the initial order, and requesting a refund. This can be a useful back door, especially given that Minnesota law generally disfavors reconsideration of the merits of the tax liability once the appeal date from the Commissioner’s Order has been missed.
There are lots of procedural nuances to Minnesota tax law. It helps to practice here on a regular basis.
This is not legal advice.