If the tax commissioner denies any portion of a taxpayer's request for a refund, the taxpayer has the right to protest and the right to administrative review only when such protest or review is specifically provided by the statutes governing the specific tax type. When there is no specific statutory provision giving a taxpayer the right of administrative review, the decision by the tax commissioner is final and irrevocable.
N.D. Admin Code 81-01.1-02-02
General Authority: NDCC 28-32-02
Law Implemented: NDCC 57-01-02