At least ninety days prior to said disclosure of the name of any such delinquent taxpayer, the commissioner shall mail a written notice to each such delinquent taxpayer by certified mail addressed to such delinquent taxpayer at his last or usual place of business or abode detailing the amount and nature of this delinquency and the intended disclosure of this delinquency. If the delinquent tax has not been paid sixty days after said notice, the commissioner shall disclose such tax in said list of delinquent taxpayers.
Unpaid taxes shall not be deemed to be delinquent and subject to disclosure if a written agreement for payment exists without default between the taxpayer and the commissioner; or the commissioner certifies that the tax liability is under appeal or is based wholly upon a question of law that is currently under appeal before a court or the appellate tax board in another case involving the same question.
Any unauthorized disclosure made by the commissioner in good faith effort to comply with this paragraph shall not be considered a violation of this section.
Mass. Gen. Laws ch. 62C, § 21