§ 28-12. Appeal of decision on refund or revision.

(a) Administrative appeal.

(1) Within 15 days of notice of action by the Director on the taxpayer's application for revision or refund of an assessment, the taxpayer may request a formal hearing before the Director.

(2) The Director shall grant a hearing and shall give the taxpayer reasonable notice of the time, date, and place of the hearing.

(b) Conduct of hearing.

The Director shall have the power:

(1) to administer oaths; and

(2) to prescribe all necessary and reasonable rules for the conduct of a hearing.

(c) Director's decision.

(1) After a hearing, the Director:

(i) shall make a determination concerning any revision of the assessment, or grant or refuse a refund; and

(ii) shall provide notice to the taxpayer of this determination.

(2) In addition, the Director may levy a deficiency assessment against the taxpayer for any additional taxes found to be due.

(d) Judicial review.

(1) A taxpayer dissatisfied with the Director's final determination may seek judicial review of that decision by petition to the Circuit Court for Baltimore City in accordance with the Maryland Rules of Procedure.

(2) A party to the judicial review may appeal the court's final judgment to the Court of Special Appeals in accordance with the Maryland Rules of Procedure.