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Any taxpayer against whom the Tax Commission has assessed taxes, penalties, or interest pursuant to any tax law of the Osage Nation, and who has paid under written protest any taxes, penalties, or interest assessed by the Tax Commission who believes those taxes, penalties, or interest to be wrongfully assessed or collected, may appeal in writing for a full hearing before the Tax Commission under such rules and regulations as the Tax Commission may prescribe. No proceeding instituted by the Tax Commission to collect a tax liability may be stayed because of a request made by a taxpayer to adjust or abate an assessment alleged to be clearly erroneous. ONCA 06-10, eff. Sept. 29, 2006; ONCA 14-83, eff. Nov. 24, 2014.