Tax Attorney in Salem, NH

Federal IRS representation for Salem, New Hampshire individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at the trial sessions held in Boston at the John W. McCormack Post Office and Courthouse on Post Office Square, 35 miles south of Salem. We also coordinate New Hampshire Department of Revenue Administration matters under Form 2848 Power of Attorney where they sit alongside a federal case, and we run the unique NH-resident / MA-commuter wage-tax exposure that hits Salem households commuting to Andover, Lowell, or Boston.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: May 25, 2026.

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Serving Salem, Windham, Pelham, Derry, Londonderry, Hampstead, Atkinson, Plaistow, all of Rockingham County, and the broader NH-MA border tier

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If you owe back taxes in Salem, NH, here is the 2026 picture

New Hampshire is now one of nine United States with no broad personal income tax. The Interest and Dividends Tax under RSA 77 — the last narrow investment-income tax in the country — was repealed effective January 1, 2025, finishing a phased sunset that began in 2023. Salem residents owe zero New Hampshire tax on wages, salaries, retirement distributions, Social Security, capital gains, dividends, and interest. The state still operates a 7.5% Business Profits Tax under RSA 77-A for entities with gross receipts above $92,000, a 0.55% Business Enterprise Tax under RSA 77-E, a 9% Meals and Rentals Tax under RSA 78-A, and a 5% Real Estate Transfer Tax under RSA 78-B. There is no state sales tax. The combined effect is one of the lightest state tax footprints in the country — which is exactly why a steady stream of Massachusetts, New York, Connecticut, and Rhode Island households have relocated to Salem, Windham, and the I-93 corridor over the past five years.

The catch for many Salem households is the cross-border wage problem. Approximately one in three working Salem residents commutes to Massachusetts — Andover, Lowell, Tewksbury, Burlington, Woburn, Cambridge, and Boston. Massachusetts taxes that wage income at its flat 5% rate under M.G.L. Ch 62 § 4(b), plus the 4% Millionaires Tax surcharge above $1 million under M.G.L. Ch 62 § 4(d). New Hampshire has no income tax and therefore no reciprocal credit to offset the MA tax. The net result is that a Salem-resident MA-commuter pays the full Massachusetts tax on Massachusetts-source wages with no state-level relief from New Hampshire. If you have received an IRS CP504, LT11, Statutory Notice of Deficiency, or a Massachusetts DOR Notice of Assessment on your MA-source wages, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED under IRC § 6502, file Form 2848 federally, file Form M-2848 with the Massachusetts DOR if there is a parallel state case, and pause collection while the resolution is built.

Federal tax representation for Salem, NH taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases — holds regular trial sessions in Boston at the John W. McCormack Post Office and Courthouse, 5 Post Office Square, 35 miles south of Salem. Boston is the designated New England trial city for petitioners from New Hampshire, Vermont, Maine, Rhode Island, and Massachusetts. From our Robertson Boulevard office in Los Angeles, we represent Salem residents and New Hampshire-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For New Hampshire state-tax matters — the 7.5% Business Profits Tax under RSA 77-A, the 0.55% Business Enterprise Tax under RSA 77-E, the 9% Meals and Rentals Tax under RSA 78-A, the 5% Real Estate Transfer Tax under RSA 78-B, town-level property-tax appeals, or contested matters headed to the New Hampshire Board of Tax and Land Appeals under RSA 71-B — we file IRS Form 2848 with the New Hampshire Department of Revenue Administration (the DRA accepts the federal POA form, with the New Hampshire-specific version available through the DRA) and handle the administrative track directly. For formal litigation before the NH Board of Tax and Land Appeals or in the New Hampshire Superior Court (Rockingham County sits in Brentwood), we coordinate with locally admitted New Hampshire counsel under a co-counsel arrangement. Because New Hampshire has no broad personal income tax, the typical Salem engagement is heavily federal-weighted — which is exactly where our firm carries the load.

For Salem residents commuting to Massachusetts, the engagement often runs three layers: the IRS federal case under Form 2848, the Massachusetts DOR state case on MA-source wages under Form M-2848, and the New Hampshire DRA layer if a Business Profits Tax, Business Enterprise Tax, or property-tax issue is in play. We coordinate all three. Salem sits at a geography that produces a steady stream of these cross-border cases: 30 miles north of Boston, five miles from the Massachusetts state line at Methuen, home to the Mall at Rockingham Park (one of the largest tax-free shopping destinations in the United States outside the four no-sales-tax states), Canobie Lake Park (the oldest continuously operating amusement park in the country, established 1902), Liberty Mutual's Salem campus, Fidelity Investments back-office operations, Parkland Medical Center, and a Rockingham Park casino legacy that closed in 2016 but still generates W-2G and 1099 cleanup. The federal procedures are uniform; the Salem facts are particular.

Your tax rights as a Salem, NH taxpayer

Three rights frameworks may apply to a Salem taxpayer. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. New Hampshire rights come from RSA Title V, the Taxation Code, and the procedural rules of the NH Board of Tax and Land Appeals. Massachusetts rights apply if you commute to MA and have MA-source wage income subject to MA DOR enforcement. Knowing which apply to your facts is the difference between a clean resolution and a missed 30-day BTLA petition window that locks in an assessment against your Salem home.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS must deal with us first, not you. The New Hampshire DRA accepts Form 2848 for state-level matters; Massachusetts requires Form M-2848 for any parallel MA DOR case.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The U.S. Tax Court holds regular trial sessions in Boston at 5 Post Office Square, 35 miles south of Salem and the designated New England trial city for all NH petitioners.

Right to NH Board of Tax and Land Appeals review

RSA 71-B establishes the New Hampshire Board of Tax and Land Appeals (BTLA), the state's specialized administrative tribunal for property-tax abatements and state-tax appeals. The BTLA sits at 107 Pleasant Street, 4th Floor, Concord NH. The petition window for property-tax appeals is 30 days from the local assessor's denial, and for state-tax appeals from the DRA is generally 30 days from the assessment notice — one of the shorter petition windows in the country. Missing it forfeits the right to administrative review.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review through the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. New Hampshire has no broad personal income tax and therefore no state OIC for individuals on wages or interest income; the DRA does consider abatement requests on Business Profits Tax, Business Enterprise Tax, and Meals and Rentals Tax under RSA 21-J:28-b. For a Salem resident with MA-source wages, the Massachusetts Offer in Final Settlement program under M.G.L. Ch 62C § 37A is available on the MA side of the case.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Salem, NH taxpayers

Offer in Compromise under IRC § 7122

We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For Salem business owners carrying a New Hampshire Business Profits Tax balance under RSA 77-A or a Meals and Rentals Tax balance under RSA 78-A — the latter is common for Salem restaurant and inn operators — we coordinate parallel DRA abatement filings under RSA 21-J:28-b on the same financial showing.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — the most under-used path for Salem households carrying $50,000 to $250,000 in federal debt, particularly NH-resident MA-commuter families whose Massachusetts withholding got reset during COVID-era remote-work shifts and produced a federal underpayment alongside the state one.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Salem-area property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Rockingham County Registry of Deeds in Brentwood encumber title on properties in Salem, Windham, Pelham, Derry, Londonderry, Hampstead, Atkinson, and the rest of southern Rockingham County. The IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing date.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. New Hampshire does not impose a state wage levy on personal income because the state has no personal income tax. Massachusetts can levy MA-source wages of NH-resident commuters under M.G.L. Ch 62C § 50 if there is an unpaid Massachusetts assessment.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, retail Schedule C reconstruction for Salem tax-free-shopping retailers, hospitality Form 8027 tip-reporting for Canobie Lake Park-area restaurants, and NH-MA wage-source disputes under the Cohen v. Wadlin Hill and AGI v. MA line of cases. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. New England trial sessions are held in Boston at the McCormack Courthouse.

Penalty abatement under IRC § 6651 and IRM 20.1.1

First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. New Hampshire DRA penalties on Business Profits Tax under RSA 21-J:31 (failure to file) and RSA 21-J:33 (substantial understatement) follow a separate reasonable-cause analysis applied by the DRA and reviewable by the NH Board of Tax and Land Appeals.

Twelve types of Salem, NH tax matters we handle

Federal cases for Salem residents and New Hampshire-domiciled businesses, framed against the NH DRA overlay where it applies and the Massachusetts DOR overlay where a cross-border wage issue is in play.

NH-MA commuter wage-tax squeeze

Salem residents commuting to Andover, Lowell, Tewksbury, Burlington, Woburn, Cambridge, or Boston earn Massachusetts-source wages under the convenience-of-the-employer-state's-rule analysis. Massachusetts taxes those wages at 5% under M.G.L. Ch 62 § 4(b), plus the 4% Millionaires Tax surcharge above $1 million under M.G.L. Ch 62 § 4(d). New Hampshire offers no reciprocal credit because the state has no personal income tax. The post-COVID litigation history (Cohen v. Wadlin Hill 2018, the New Hampshire v. Massachusetts Supreme Court petition 2021, and the Massachusetts emergency remote-work-source regulations of 2020-2022) shaped how MA characterizes remote workdays. A clean wage-source analysis, working-day count, and Form 1-NR/PY are the building blocks.

NH residency audit and domicile substantiation

Massachusetts, New York, Connecticut, and Rhode Island aggressively audit purported moves to New Hampshire. The factor tests look at home location, time in state, family ties, professional ties, vehicle registration, voter registration, primary-care physician location, where pets live, where personal records are kept, and where the calendar shows the taxpayer was on each day of the year. A relocation from Andover, Lowell, Cambridge, Boston, Westchester County, Fairfield County, or Providence to Salem produces a domicile contest with real money on the line. We build the factor record and the day-count documentation that survives a Massachusetts DOR Audit Bureau review.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Salem restaurant operators (Routes 28 and 38 corridors), Canobie Lake Park-adjacent hospitality, Liberty Mutual contractors, Mall at Rockingham Park retail tenants, and construction firms are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons; New Hampshire does not have a parallel personal income-tax withholding regime, but Meals and Rentals Tax under RSA 78-A:7 carries similar trust-fund liability to the DRA.

Salem tax-free-shopping retailer Schedule C reconstruction

Salem is a retail destination because New Hampshire has no state sales tax. The Mall at Rockingham Park, Cabela's, Walmart, Target, Costco, and the surrounding big-box and boutique stores along Route 28 draw heavy Massachusetts cross-border foot traffic. Schedule C and Schedule E retailer cases — cash-register reconciliation, inventory-method election under IRC § 471, COGS substantiation, and unreported cash deposits — are a steady book. IRS Form 8300 cash-receipt reporting for purchases over $10,000 lands frequently in this sector.

Hospitality W-2G and Form 8027

Canobie Lake Park (operating since 1902, the oldest continuously running U.S. amusement park), the Hampton Beach tourism corridor 15 miles east, and the Mall at Rockingham Park food court produce W-2G gambling-payout cleanup from the legacy Rockingham Park casino era, Form 8027 large-food-or-beverage tip-reporting work, and 1099 worker-misclassification disputes under IRC § 3509 and the Section 530 safe harbor.

Notice of Federal Tax Lien

NFTLs filed with the Rockingham County Registry of Deeds in Brentwood encumber title and trigger CDP rights under IRC § 6320. New Hampshire's Real Estate Transfer Tax under RSA 78-B applies to any transfer of NH real property at a 0.75% rate per side (1.5% combined). When a Salem closing is set, an NFTL on the title can stall the deal until a discharge or subordination under IRC § 6325 is in place.

IRS bank or wage levy

Bank levies on accounts held at TD Bank, Citizens, Bank of America, Eastern Bank, Enterprise Bank, Pentucket Bank, or any New Hampshire-chartered institution serving the Salem area. Wage levies hit Salem employers within days of CP90 or LT11 issuance — including Liberty Mutual, Fidelity Investments, Parkland Medical Center, Salem Memorial, the Salem School District, the Town of Salem, and the Mall at Rockingham Park retail tenants.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Salem's large Indian-American, Hispanic, and Asian-American population, dual-citizen business owners, and Boston Logan International Airport 35 miles south as a major international gateway, this lands hard on families with overseas business or family obligations. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Salem's Indian-American, Hispanic, Brazilian, and Asian-American populations carry steady FBAR exposure on overseas accounts inherited from family or maintained for cross-border business. ITIN engagements (Form W-7) and the IRS Streamlined Filing Compliance Procedures are a frequent track.

Real-estate sale and STR cases

Canobie Lake-adjacent and Hampton Beach short-term-rental investors face IRC § 280A material-participation tests, the seven-day average-rental rule, IRC § 469 passive-activity loss limits, and IRC § 1031 like-kind exchange procedural traps. New Hampshire imposes a 9% Meals and Rentals Tax under RSA 78-A on short-term rentals of nine days or less — one of the higher state-level rates in the country and a frequent DRA audit target.

Innocent Spouse Relief

IRC § 6015 relief for spouses jointly liable on a return where the other spouse's items caused the deficiency. We file Form 8857 with a clean factual record — common in divorces where one spouse held the MA-source W-2 income, the construction-business 1099 income, or the Schedule C retail income, and the other spouse signed the joint return without seeing the underlying tax position.

Cryptocurrency tax assessments

CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. New Hampshire's libertarian and crypto-friendly policy stance has produced a higher-than-average concentration of retail crypto activity in the Salem-Windham-Manchester triangle. Form 1099-DA reporting (effective 2025) drives the matching cases. Because New Hampshire has no personal income tax, the federal layer is the only state-or-federal exposure for individual Salem holders.

Nine common causes of tax debt for Salem, NH taxpayers

Patterns we see repeatedly in Salem-based engagements. None of them are unusual — all of them are resolvable.

1. NH-MA commuter underwithholding

A Salem resident working in Andover, Lowell, or Cambridge files Massachusetts Form 1-NR/PY at the 5% MA rate with no New Hampshire offset. If the employer withheld at the wrong state code, or if remote work days during 2020-2024 produced disputed MA-source allocations, the federal return reconciles fine but the MA balance lands due in April. Federal underpayment penalties under IRC § 6654 follow on the federal side when MA withholding was over-allocated to NH.

2. Self-employment underpayment

Salem-area contractors, electricians, plumbers, HVAC technicians, Mall at Rockingham Park retail tenants, Parkland Medical Center attending physicians with 1099 side practices, and real-estate agents file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

3. Business closure

When an LLC, S-corp, restaurant, or retail business closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. The post-pandemic Salem restaurant and retail churn produced a wave of these cases. Parallel New Hampshire Meals and Rentals Tax trust-fund liability under RSA 78-A:7 attaches to the same responsible person.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted. The cross-border NH-MA element complicates the file when one spouse had MA-source wages and the other spouse did not.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Cross-border NH-MA cases occasionally involve a fraudulent MA Form 1 filed alongside the federal one, which requires a parallel Massachusetts identity-theft filing.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price. Because NH has no personal income tax, the federal CP2000 is the only state-or-federal layer for individual Salem holders — but the federal layer carries the full 37% top marginal rate.

7. Late-filed or unfiled returns

Failure-to-file under IRC § 6651(a)(1) compounds at 5% per month, capped at 25%. After three years, refunds are barred under IRC § 6511. New Hampshire DRA mirrors a similar approach on Business Profits Tax and Business Enterprise Tax filings under RSA 21-J:31.

8. Real-estate sale without estimated tax

A Salem, Windham, Pelham, or Derry sale generating substantial capital gain, with no Form 1040-ES payment, produces a federal tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules of IRC § 1221. The New Hampshire Real Estate Transfer Tax under RSA 78-B is collected at closing separately.

9. Retirement account distribution surprises

Salem attracts a heavy retiree-relocation flow from Massachusetts, New York, and Connecticut precisely because New Hampshire taxes neither earned income nor (now) interest and dividends. Early 401(k) and IRA distributions under IRC § 72(t) and required-minimum-distribution mistakes under IRC § 401(a)(9) produce federal-side balances due. The state-side cushion that motivated the move does not exist at the federal level — a common surprise for first-year Salem retirees.

Eight tax liabilities that pull in Salem, NH taxpayers

Federal authority alongside the New Hampshire or Massachusetts statute where there is a parallel.

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The New Hampshire mirror under RSA 21-J:31 applies only to Business Profits Tax, Business Enterprise Tax, Meals and Rentals Tax, and similar business and excise filings — because there is no personal income tax, there is no NH penalty on a Salem individual who fails to file a state personal return.

Massachusetts non-resident return for MA-commuter

A Salem resident with Massachusetts-source wages must file Massachusetts Form 1-NR/PY under M.G.L. Ch 62 § 5A. Failure to file triggers M.G.L. Ch 62C § 33 (1% per month, capped at 25%) and the 60-day Appellate Tax Board petition window under M.G.L. Ch 58A § 7 once the DOR issues a Notice of Assessment.

Federal § 7122 Offer in Compromise eligibility

All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.

New Hampshire Business Profits Tax

RSA 77-A imposes a 7.5% Business Profits Tax on every business organization with gross receipts above $92,000. The tax is computed on apportioned New Hampshire-source profits. A Salem-area S-corp, LLC, or partnership pays BPT at the entity level — not at the owner level — which is the central tax-planning difference between New Hampshire and the surrounding states. Failure to file or substantial understatement carries the RSA 21-J penalty stack.

New Hampshire Business Enterprise Tax

RSA 77-E imposes a 0.55% Business Enterprise Tax on the sum of compensation paid, interest paid, and dividends paid by an enterprise with gross receipts above $281,000. The BET is creditable against BPT, so most Salem entities pay one or the other, not both. The BET catches partnerships, sole proprietorships, and pass-throughs that BPT alone might miss.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. New Hampshire applies a parallel responsible-person rule to unpaid Meals and Rentals Tax under RSA 78-A:7 and to unpaid Business Profits Tax withheld at the entity level under RSA 77-A:6.

Accuracy-related penalty

IRC § 6662 imposes 20% on substantial-understatement or negligence; IRC § 6663 imposes 75% on fraud. Defense is built on substantial authority, adequate disclosure, or reasonable cause. New Hampshire DRA applies parallel penalties under RSA 21-J:33 on Business Profits Tax, Business Enterprise Tax, and Meals and Rentals Tax assessments.

New Hampshire Real Estate Transfer Tax

RSA 78-B imposes a 0.75% Real Estate Transfer Tax on each side of the transaction (1.5% combined) for any transfer of New Hampshire real property. It is collected at closing through the Rockingham County Registry of Deeds and is one of the few transaction-level taxes a Salem property seller will see. Misreported sale price or undisclosed assumed liabilities trigger DRA audits.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Rockingham County Registry of Deeds.

Sample tax-resolution outcomes

Anonymized client matters drawn from our $100M+ aggregate tax-relief record across 2,000+ resolved cases.

Year	Tax debt	Resolution	Final outcome
2024	$152,296	IRC § 6159 Installment Agreement	Accepted at $25/month, partial-pay
2024	$138,296	Streamlined Installment Agreement	Accepted at $25/month
2023	$130,555	Partial-Pay Installment Agreement	Accepted at $50/month
2023	$128,206	IRC § 6159 Installment Agreement	Accepted at $25/month
2022	$116,451	Partial-Pay Installment Agreement	Accepted at $50/month

Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service, the New Hampshire Department of Revenue Administration, and the Massachusetts Department of Revenue.

Why Victory Tax Lawyers for a Salem, NH federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not New Hampshire-Bar-admitted and not Massachusetts-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Boston at the John W. McCormack Post Office and Courthouse on Post Office Square, the designated New England trial city for all New Hampshire petitioners. IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Salem clients never need a separately admitted New Hampshire or Massachusetts attorney because the case is, at its core, federal — and federal is precisely where New Hampshire's lack of a state personal income tax pushes the entire tax exposure.

For administrative work before the New Hampshire Department of Revenue Administration — Business Profits Tax protests under RSA 77-A, Business Enterprise Tax audits under RSA 77-E, Meals and Rentals Tax assessments under RSA 78-A, Real Estate Transfer Tax inquiries under RSA 78-B, and abatement requests under RSA 21-J:28-b — we file Form 2848 with the DRA and handle the matter remotely. For administrative work before the Massachusetts DOR on a Salem-resident MA-commuter wage case, we file Form M-2848. When a case must move to the New Hampshire Board of Tax and Land Appeals (RSA 71-B, 107 Pleasant Street 4th Floor in Concord), the Rockingham County Superior Court in Brentwood, the Massachusetts Appellate Tax Board, or the Massachusetts Appeals Court, we coordinate with locally admitted New Hampshire or Massachusetts counsel under a co-counsel arrangement. The federal portion of the engagement — which is the largest piece for almost every Salem matter precisely because NH has no personal income tax — stays with our firm.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a New Hampshire-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Salem taxpayer, at the same standard we apply to a Los Angeles or Manchester client. Our 100% remote workflow runs through a secure document portal — you never have to travel to Robertson Boulevard, and you save the 35-mile trip to Boston for U.S. Tax Court only when the case actually goes to trial.

Our seven-step process for Salem, NH clients

Free consultation

A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.

Engagement letter

A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.

Form 2848 and CAF

We file the federal Power of Attorney with the IRS, file Form 2848 with the New Hampshire DRA where applicable, and file Form M-2848 with the Massachusetts DOR where a MA-source wage case is in play. We register on the CAF system and step in as the contact of record.

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or an NH BTLA petition through local counsel — and handle every IRS, DRA, and DOR contact.

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Federal CSED, New Hampshire collection rules, and the Massachusetts six-year clock

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more.

New Hampshire has no broad personal income tax and therefore no state personal-income CSED to track. The DRA's Business Profits Tax, Business Enterprise Tax, Meals and Rentals Tax, and Real Estate Transfer Tax follow the assessment-and-collection rules in RSA 21-J:28 and related provisions, with a generally three-year assessment statute that can extend in cases of substantial omission or fraud. For Salem residents commuting to Massachusetts, the parallel Massachusetts collection clock under M.G.L. Ch 62C § 65 runs six years from the date of MA assessment, renewable by re-recording the state tax lien. Many Salem cross-border households carry a federal CSED running on a different timeline than their Massachusetts collection statute — pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Salem, NH tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices that touch a Salem case is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Salem, NH matter.

Internal Revenue Service — Manchester NH TAC

The federal tax authority, at irs.gov. There is no IRS Taxpayer Assistance Center in Salem itself; the closest is the Manchester NH TAC at 1000 Elm Street, Room 1004, Manchester NH 03101, roughly 35 miles west via I-93. Appointments required. The Boston TAC at 25 New Sudbury Street is roughly the same distance south for Salem residents who prefer a Boston-side appointment.

U.S. Tax Court — Boston trial sessions

The U.S. Tax Court holds regular trial sessions in Boston at the John W. McCormack Post Office and Courthouse, 5 Post Office Square, the designated New England trial city for all New Hampshire petitioners. Salem residents file the petition naming Boston as the requested trial location; the 35-mile trip south is the only required courthouse visit on most cases. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

New Hampshire Department of Revenue Administration

The state tax authority, at revenue.nh.gov. Headquartered at 109 Pleasant Street, Concord NH 03301. Administers the 7.5% Business Profits Tax under RSA 77-A, the 0.55% Business Enterprise Tax under RSA 77-E, the 9% Meals and Rentals Tax under RSA 78-A, the Real Estate Transfer Tax under RSA 78-B, and the now-repealed (effective 2025) Interest and Dividends Tax. No state personal income tax. No state sales tax.

New Hampshire Board of Tax and Land Appeals

The state's specialized administrative tax-and-land tribunal, established under RSA 71-B. Seated at 107 Pleasant Street, 4th Floor, Concord NH. Hears property-tax abatement petitions, state-tax appeals from DRA assessments, current-use disputes, and timber-tax matters. Generally a 30-day petition deadline from the local assessor's denial or the DRA's assessment notice — one of the shorter petition windows in the country. Decisions are appealable to the New Hampshire Supreme Court on questions of law. Victory Tax Lawyers refers BTLA litigation to locally admitted New Hampshire counsel; we handle the federal portion and the DRA administrative work directly.

Town of Salem Tax Collector and Assessing Department

The municipal authority for Salem property tax and town tax-collection. Office at the Salem Municipal Building, 33 Geremonty Drive, Salem NH 03079. Page: townofsalemnh.org. Administers the Salem real-property tax, motor-vehicle registration tax, current-use applications under RSA 79-A, and property-tax abatement applications under RSA 76:16 (60-day filing window from the tax bill). Salem is a town in Rockingham County; New Hampshire has no county-level government for towns, so all local taxation is run at the town level.

Rockingham County and Registry of Deeds

Salem sits in Rockingham County. The Rockingham County Sheriff's Office is at 10 Court Street, Brentwood NH 03833, and the Rockingham County Superior Court (the trial-level state court that handles tax-related civil matters beyond BTLA jurisdiction) is in the same Brentwood complex. The Rockingham County Registry of Deeds records Notices of Federal Tax Lien affecting Salem-located real property; an NFTL recorded against the wrong county fails to attach to title, which is the procedural defect that supports lien-withdrawal requests under Form 12277.

U.S. District Court — District of New Hampshire

Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court for the District of New Hampshire, located at the Warren B. Rudman United States Courthouse, 55 Pleasant Street, Concord NH 03301, the U.S. District Court for the District of Massachusetts in Boston, or the U.S. Court of Federal Claims in Washington, D.C. Salem litigants frequently have a choice of forum given the location and the cross-border facts.

Massachusetts Department of Revenue — for MA-commuter cases

For Salem residents earning Massachusetts-source wages, the Massachusetts DOR at 100 Cambridge Street, Suite 800, Boston MA 02114, is the state tax authority on the MA side. Administers the flat 5% personal income tax under M.G.L. Ch 62 § 4(b), the 4% Millionaires Tax surcharge above $1 million under M.G.L. Ch 62 § 4(d), and non-resident filing on Form 1-NR/PY under M.G.L. Ch 62 § 5A. The 60-day Appellate Tax Board petition window under M.G.L. Ch 58A § 7 applies to a Salem resident's MA non-resident return as it would to a Boston resident.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Salem cases run through the Appeals offices serving the New England region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — New Hampshire

An independent organization within the IRS that helps when normal channels stall. The Local Taxpayer Advocate office serving New Hampshire is based in Boston and covers Massachusetts and the broader northern New England region. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Salem, NH matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, an NH DRA Notice of Assessment, or a Massachusetts DOR Notice of Assessment on your MA-source wages is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Salem, NH tax

Does New Hampshire have a state income tax in 2026?

No. New Hampshire is one of nine U.S. states with no broad personal income tax. The narrow Interest and Dividends Tax under RSA 77 — long the country's last investment-income-only state tax — was fully repealed effective January 1, 2025, finishing a phased sunset that began at the 4% rate in 2023 and the 3% rate in 2024. A Salem resident in 2026 owes zero New Hampshire tax on wages, salaries, retirement distributions, Social Security, interest, dividends, or capital gains. New Hampshire still operates a 7.5% Business Profits Tax under RSA 77-A on entities with gross receipts above $92,000, a 0.55% Business Enterprise Tax under RSA 77-E, a 9% Meals and Rentals Tax under RSA 78-A, a 5% Real Estate Transfer Tax under RSA 78-B (0.75% per side, 1.5% combined), and town-level property taxes that are among the highest in the country — the tax footprint is shifted away from income and toward business and property.

I live in Salem and work in Massachusetts — what state tax do I owe?

Massachusetts taxes your MA-source wages at 5% under M.G.L. Ch 62 § 4(b), plus the 4% Millionaires Tax surcharge above $1 million under M.G.L. Ch 62 § 4(d). You file Massachusetts Form 1-NR/PY as a non-resident. New Hampshire has no personal income tax and therefore offers no reciprocal credit — you pay the full Massachusetts tax on your MA-source wages with no NH offset. This is the classic NH-MA commuter squeeze. The exact source allocation matters: physical workdays in MA vs. remote workdays from your Salem home drive the MA-source percentage. The Massachusetts emergency remote-work-source regulations of 2020-2022, the New Hampshire v. Massachusetts Supreme Court petition of 2021, and the Cohen v. Wadlin Hill line of cases shape how MA characterizes those workdays.

Where is the closest U.S. Tax Court trial location to Salem?

Boston, at the John W. McCormack Post Office and Courthouse, 5 Post Office Square, 35 miles south of Salem via I-93. Boston is the designated New England trial city for all U.S. Tax Court petitioners from New Hampshire, Vermont, Maine, Rhode Island, and Massachusetts. A Salem petitioner files the Tax Court petition naming Boston as the requested trial location. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

What is the New Hampshire Board of Tax and Land Appeals?

The New Hampshire Board of Tax and Land Appeals (BTLA) is the state's specialized administrative tax-and-land tribunal, established under RSA 71-B. It sits at 107 Pleasant Street, 4th Floor, Concord NH, and hears property-tax abatement petitions, state-tax appeals from DRA assessments, current-use disputes under RSA 79-A, and timber-tax matters. The petition window is generally 30 days from the local assessor's denial or the DRA's assessment notice — one of the shorter petition windows in the country, and significantly tighter than the 60-day Massachusetts Appellate Tax Board window or the 90-day federal Tax Court window. Missing it forfeits the right to administrative review. Decisions are appealable to the New Hampshire Supreme Court on questions of law. Victory Tax Lawyers refers BTLA litigation to locally admitted New Hampshire counsel.

Does Salem have a county tax authority?

No. New Hampshire has no county-level government for towns — an arrangement unique to a few states. Salem is a town in Rockingham County, but all local taxation runs at the town level through the Town of Salem Tax Collector and Assessing Department at 33 Geremonty Drive. Rockingham County operates the Sheriff's Office (10 Court Street, Brentwood), the Superior Court (also in Brentwood), and the Registry of Deeds (where Notices of Federal Tax Lien on Salem-located property are recorded). There is no Rockingham County income tax, no Rockingham County sales tax, and no Rockingham County property tax — the county is a judicial and recording jurisdiction, not a taxing one.

What if I run a Mall at Rockingham Park retail business and have Schedule C exposure?

Salem retailers benefit from no New Hampshire sales tax, which is exactly why Massachusetts and southern New England residents make the trip up I-93. The flip side is that the IRS pays close attention to retailers in the tax-free zone for cash-deposit, inventory, and COGS reconstruction. We handle Schedule C reconstruction, IRC § 471 inventory-method election work, IRC § 446 accounting-method changes, Form 8300 cash-receipt reporting for purchases above $10,000, and IRS Information Document Request responses on bank-deposit analysis. On the New Hampshire side, a Salem retailer with gross receipts above $92,000 owes 7.5% Business Profits Tax under RSA 77-A and may owe the 0.55% Business Enterprise Tax under RSA 77-E (creditable against BPT).

I run a restaurant or inn in Salem — what is the Meals and Rentals Tax?

RSA 78-A imposes a 9% Meals and Rentals Tax on the sale of meals, alcoholic beverages, and rental of hotel rooms and short-term vacation rentals of nine days or less. The operator collects the M&R Tax from the customer and remits monthly to the New Hampshire Department of Revenue Administration. Failure to remit triggers personal trust-fund liability on the responsible officer under RSA 78-A:7 — the New Hampshire parallel to the federal IRC § 6672 Trust Fund Recovery Penalty. The 9% rate is one of the highest state-level lodging-and-meals rates in the country, which is what makes it a top DRA audit target.

Massachusetts is auditing my move to Salem — what do they look for?

The Massachusetts DOR Audit Bureau looks at primary residence location, days physically present in MA each year (the 183-day count under M.G.L. Ch 62 § 1(f) is one threshold; the domicile analysis is a separate one), vehicle registration, voter registration, primary-care physician location, where pets and children live, where personal records are kept, where the safe-deposit box is, where the will is filed, where the homestead declaration is filed, employer payroll address, club memberships, religious-organization affiliations, charitable-gift records, and credit-card geographic activity. A relocation from Andover, Lowell, Cambridge, Boston, Westchester County, Fairfield County, or Providence to Salem produces a domicile contest because the move saves five or six figures of state tax each year. We build the factor record and the day-count documentation that survives a DOR Audit Bureau review.

Can a California-Bar-admitted attorney represent me in Salem?

For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Boston. For New Hampshire DRA administrative work, we file Form 2848 with the DRA and handle the matter remotely. For Massachusetts DOR administrative work on a MA-source wage case, we file Form M-2848. For formal litigation before the New Hampshire Board of Tax and Land Appeals, the Rockingham County Superior Court in Brentwood, the Massachusetts Appellate Tax Board, or any state-court proceeding, we co-counsel with locally admitted New Hampshire or Massachusetts attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled federal returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Because New Hampshire has no personal income tax, there is no NH state-side filing-compliance requirement for an individual Salem resident on wages or investment income — the federal layer is the entire compliance picture. If MA-source wages are in play, Massachusetts non-resident returns on Form 1-NR/PY must also be brought current under M.G.L. Ch 62C § 26.

Can the IRS levy my Salem bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at TD Bank, Citizens, Bank of America, Eastern Bank, Enterprise Bank, Pentucket Bank, or any New Hampshire-chartered institution serving the Salem area, and serve wage levies on Salem employers including Liberty Mutual, Fidelity Investments, Parkland Medical Center, the Salem School District, the Town of Salem, and Mall at Rockingham Park retail tenants. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1).

I just retired and moved to Salem from Massachusetts — what changes federally?

Federal rules do not change with the move — IRC § 72(t) early-distribution rules, IRC § 401(a)(9) required-minimum-distribution rules, IRC § 86 Social Security taxability, and IRC § 691(c) income-in-respect-of-decedent treatment apply the same in Salem as in Boston. What changes is the state layer: New Hampshire has no personal income tax in 2026, so your IRA, 401(k), 403(b), 457(b), and pension distributions are not subject to state tax, and your Social Security benefits are not subject to state tax (which Massachusetts also exempts at the state level, but the Massachusetts 5% on IRA and 401(k) distributions and the 4% Millionaires Tax surcharge above $1 million both disappear with the move). The big surprise for first-year Salem retirees is realizing that the federal layer is the entire tax exposure — which is exactly the planning opportunity the relocation was meant to capture.

How long does a federal Offer in Compromise take to process?

An IRS Offer in Compromise typically takes six to twelve months from filing to a final decision. The IRS deems an Offer accepted if not rejected within 24 months under IRC § 7122(f). While the OIC is pending, IRC § 6331(k) bars most levies, and the CSED is tolled. Rejected offers carry a 30-day Appeals window. A well-documented Offer with a complete Form 433-A(OIC) or 433-B(OIC) financial package moves faster than one returned for incompleteness.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement or OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. The same pattern applies on a parallel Massachusetts DOR collection case for Salem MA-commuters with an unpaid MA assessment.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $100 million in tax relief for clients across all 50 states.

Page last reviewed: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every New Hampshire statute citation references the New Hampshire Revised Statutes Annotated (RSA). Every administrative authority links to its primary .gov source. Material changes to the law are reflected within 30 days of effective date.

Attorney Advertising. This page is provided by Victory Tax Lawyers, LLP for general informational purposes only. Nothing on this page constitutes legal advice, creates an attorney-client relationship, or substitutes for consultation with a licensed attorney about your specific tax matter. Prior results described or referenced do not guarantee a similar outcome. Each tax case turns on its individual facts, applicable law, and the discretion of the Internal Revenue Service, the New Hampshire Department of Revenue Administration, the Massachusetts Department of Revenue, the U.S. Tax Court, the New Hampshire Board of Tax and Land Appeals, the Massachusetts Appellate Tax Board, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the State of New Hampshire or the Commonwealth of Massachusetts; where a New Hampshire or Massachusetts state-court appearance, NH Board of Tax and Land Appeals litigation, or Massachusetts Appellate Tax Board litigation is required, the firm associates with locally admitted counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

Authorities cited on this page

26 U.S.C. § 7122 — Federal Offer in Compromise
26 U.S.C. § 6159 — Installment Agreements
26 U.S.C. § 6321 — Federal Tax Lien
26 U.S.C. § 6325 — Lien Release and Discharge
26 U.S.C. § 6331 — Levy and Distraint
26 U.S.C. § 6343 — Release of Levy
26 U.S.C. § 6502 — Collection Statute Expiration
26 U.S.C. § 6213 — Tax Court Petition Window
26 U.S.C. § 6320 — CDP for Liens
26 U.S.C. § 6330 — CDP for Levies
26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
26 U.S.C. § 6672 — Trust Fund Recovery Penalty
26 U.S.C. § 6015 — Innocent Spouse Relief
26 U.S.C. § 7345 — Passport Revocation
26 U.S.C. § 7525 — Federal Tax Practitioner Privilege
26 U.S.C. § 280A — Short-term rental classification
26 U.S.C. § 1031 — Like-Kind Exchanges
26 U.S.C. § 72(t) — Early-distribution penalty
RSA 77 — New Hampshire Interest and Dividends Tax (repealed effective 2025)
RSA 77-A — New Hampshire Business Profits Tax (7.5%)
RSA 77-E — New Hampshire Business Enterprise Tax (0.55%)
RSA 78-A — New Hampshire Meals and Rentals Tax (9%)
RSA 78-B — New Hampshire Real Estate Transfer Tax (0.75% per side)
RSA 71-B — New Hampshire Board of Tax and Land Appeals
RSA 76:16 — New Hampshire town property-tax abatement procedure
RSA 79-A — New Hampshire Current Use taxation
RSA 21-J:28-b — New Hampshire DRA abatement authority
RSA 21-J:31 — New Hampshire DRA failure-to-file penalty
RSA 21-J:33 — New Hampshire DRA substantial-understatement penalty
M.G.L. Ch 62 § 4(b) — Massachusetts flat 5% personal income tax (applies to NH-MA commuters on MA-source wages)
M.G.L. Ch 62 § 4(d) — Massachusetts Fair Share Amendment / Millionaires Tax (4% surcharge above $1M)
M.G.L. Ch 62 § 5A — Massachusetts non-resident wage allocation
M.G.L. Ch 58A § 7 — Massachusetts Appellate Tax Board petition deadline
M.G.L. Ch 62C § 65 — Massachusetts six-year collection statute