Treasurer Stacy Garrity Announces Success of New Tax Appeal Process

Harrisburg, PA - Pennsylvania Treasurer Stacy Garrity today announced the success of the Board of Finance & Revenue's (BF&R) new tax appeal and mediated settlement process which started in 2025.

"This past year was the first that granted a longer timeline for submission and provided an option for mediated settlements to resolve tax disputes, and it was a success for BF&R and Pennsylvania taxpayers. These changes remove red tape and make Pennsylvania more business friendly."

Pennsylvania State Treasurer Stacy Garrity

The new timeline and mediation offering went into effect on Jan. 27, 2025, in accordance with Act 123 of 2024, which amended the Tax Reform Code of 1971.

Due to the increased timeline to file certain personal income tax (PIT) appeals to 90 days (previously 60), as of Dec. 31, 2025, BF&R was able to decide appeals in 154 cases based on merits, rather than dismissing them for jurisdiction reasons. In addition to the more consumer-friendly timeline to file an appeal, BF&R can also grant a 30-day extension if good cause is shown.

The law also extended timelines for filing applicable cases through the Board of Appeals at the Department or Revenue, which resulted in BF&R receiving 141 fewer PIT appeals having filing deadline issues at Board of Appeals.

There were 55 taxpayer requests and BF&R recommendations for mediation as of Dec. 31, 2025. Of these, 45% resulted in an amicable resolution between the taxpayer and the Department of Revenue. Mediated settlement is a no-cost option for taxpayers that increases efficiency.

BF&R has seen an overall reduction in decisions appealed to Commonwealth Court, with 378 in 2025, compared to 457 in 2024.

"The improvements from Act 123 are easy to quantify, and it's a winning solution for taxpayers, businesses and state government that saves both time and money. I'm grateful for Sen. Scott Hutchinson and Rep. Tim Briggs for championing this legislation, and I encourage those filing appeals to explore this new process to resolve tax disputes."

Pennsylvania State Treasurer Stacy Garrity

Act 123 was supported by numerous organizations, including the Pennsylvania Institute of Certified Public Accountants, the Pennsylvania Chamber of Business and Industry, the NFIB, and the Pennsylvania Society of Enrolled Agents.

"The PICPA is pleased to have worked collaboratively with the Pennsylvania Treasury Department on this legislative initiative, which ultimately became Act 123 of 2024. These changes streamline the tax appeals process for taxpayers and practitioners alike, reduce administrative friction, and further strengthen Pennsylvania's competitiveness as a place to do business-delivering tangible benefits to taxpayers."

Jennifer Cryder, CPA, CEO of the 18,000 member Pennsylvania Institute of CPAs

"The goals of Act 123 were to streamline the process of resolving tax disputes in Pennsylvania, provide flexibility to resolve disputes fairly and efficiently, and help job creators avoid costly litigation. The initial results show positive movement in all directions, which has helped to improve Pennsylvania's competitiveness for business investments. We're thankful for Treasurer Garrity and her office's efforts to shepherd these important reforms through completion."

Luke Bernstein, President & CEO, Pennsylvania Chamber of Business and Industry

"Act 123 makes the tax system more practical. The added time and the option to settle cases through mediation mean we can focus on getting to the right answer for small businesses instead of fighting through rigid procedures. Finally, a breath of fresh air, common sense in Harrisburg."

Warren Hudack EA, Hudak & Company

BF&R is an independent administrative tax court, administered by the State Treasurer, responsible for the second and final level of administrative appeal (with minor exceptions) before appealing to court. Its Board consists of three members - two are appointed by the Governor and confirmed by the Pennsylvania Senate; the third is the State Treasurer or her designee and serves as Chair.

For more information about BF&R and the tax appeal process, visit patreasury.gov/bfr.

Media contacts:
Steven Chizmar, Deputy Treasurer for Communications, [email protected] or
Jake S. Sarwar, Communications Specialist II, [email protected]