Mass. Gen. Laws ch. 62C § 31A
If a person fails to pay to the commissioner any required tax of a corporation, partnership or limited liability company and the person is personally and individually liable therefore to the commonwealth under section 5 of chapter 62B, section 7D of chapter 64C, section 7B of chapter 64G, section 16 of chapter 64H, section 17 of chapter 64I or section 6 of chapter 64L, the commissioner shall notify the person in writing at any time during the period of time that the assessment against the corporation, partnership or limited liability company remains in existence and unpaid. The person or his representative may confer with the commissioner or his duly authorized representative as to the assessment of the tax or the proposed determination that he is personally and individually liable therefore within 30 days after the date of such notification. After the expiration of 30 days from the date of the notification, the person shall be personally and individually liable for the tax of the corporation, partnership or limited liability company, which shall be considered to be assessed against the person, and a lien under section 50 upon all property and rights of property, whether real or personal, belonging to the person shall arise in favor of the commonwealth.
If such person is aggrieved by the assessment of the tax or the determination that he is personally and individually liable therefor, he may apply, in writing to the commissioner, on a form approved by him, for an abatement thereof at any time within the dates provided in section thirty-seven or within sixty days from the date of the notice under this section, whichever is later. All provisions of sections thirty-seven to thirty-nine, inclusive, shall apply to such application for abatement.
Mass. Gen. Laws ch. 62C, § 31A