Step 1 – The SCDOR will issue you a notice.

If you have an unresolved tax matter with the SCDOR, we will send you a notice. 

Notices regarding unresolved tax matters are called Proposed Assessments. Your Proposed Assessment may have a different title depending on the tax matter that needs to be resolved and the SCDOR division issuing the assessment.

Common titles include (but are not limited to):  

• Notice of Assessment
• Assessment Notice and Tax Bill
• Notice of Proposed Adjustment
• Notice of Action on License
• Proposed Assessment Report 

Your Proposed Assessment will clearly state: 

• What is being assessed, including the amount of tax, penalties, interest, and due date, if applicable
• What the SCDOR is basing those findings on
• What to do if you disagree with the Proposed Assessment, including information you need to file a protest and your rights under the Taxpayers' Bill of Rights. You must file a written protest within 90 days of the date listed on your notice.

Step 2 – You will file a protest with the SCDOR.

Deadline

If you disagree with the SCDOR’s findings on your Proposed Assessment, you have 90 days from the date of notice to file a written protest. If the 90th day of the protest period falls on a weekend or state holiday, your deadline will be extended to the next business day.

If you fail to file your written protest for an unresolved tax matter within 90 days, the SCDOR will make its final assessment and begin collection activities. 

If the SCDOR receives your written protest within 90 days of your Proposed Assessment, we will not attempt to collect any tax or take other action until the protest is resolved.

How to File Your Protest

There are three ways to file your protest with the SCDOR: online, with a C-245 form, or in writing without a C-245 form. 

Submit a protest online:

The quickest, easiest way to file a protest is by completing the Protest Pursuant to Revenue Procedures Act (C-245) using our free online tax portal, MyDORWAY.

To submit a protest online, you will need a MyDORWAY account.

1. Log in to MyDORWAY.
2. Select the Accounts tab, then scroll to the account in question.
3. Select More Account Options.
4. On the next screen, click File an Application for Appeal.

If you use MyDORWAY to file your appeal, you are required to attach or mail in a copy of the notice you received related to the appeal. We recommend scanning a copy of your notice before logging in to MyDORWAY so you can attach the copy before completing the application.

File a paper copy of the C-245:

• Download and complete the C-245.
• Send your completed form to the address or email address listed on your Proposed Assessment. You can also hand deliver it to one of our offices. 

File a written protest without using the C-245:

If you choose not to use the C-245, your protest must still contain all of the information on the C-245, including:

• Your name, mailing address, and telephone number
• Your appropriate taxpayer identification number (such as your Social Security Number, License Number, or File Number)
• The tax period or date covered in the Proposed Assessment
• The tax type and nature of your dispute
• A statement outlining the reasons for your protest, including any law or authority you are basing your protest on
• Any other relevant information
• A copy of the Proposed Assessment you are protesting 

Step 3 – We will meet to review your protest.

When we receive your protest, the SCDOR division that issued your Proposed Assessment will send you an Acknowledgement Letter.

The Acknowledgement Letter will provide information so that you can request a meeting with an SCDOR representative from that division.

Requesting a meeting:

• You have 30 days from the date listed on the Acknowledgement Letter to request a meeting with an SCDOR representative.
• This meeting is optional but strongly encouraged. An SCDOR representative will make every effort to schedule a meeting within 30 days of your request.
• The meeting can take place in-person at an SCDOR office or, if both parties agree, the meeting may be held over the phone.

At the meeting, both parties will work to determine next steps.

• The SCDOR representative will answer any questions, explain the division’s position, and seek to better understand the taxpayer’s position.
• The taxpayer may provide additional information that supports their position.
• The two parties may reach a resolution.

After the meeting, or if you have not requested a meeting within 30 days of your Acknowledgement Letter, the SCDOR division representative will conduct a full review of your protest.

• If the SCDOR representative agrees with your position, or if you mutually agree to a different position than what is stated on your original Proposed Assessment:
  • The SCDOR will send you a new Proposed Assessment that outlines the terms of your agreement.
  • Take the actions listed on the new Proposed Assessment (such as paying any tax due, if applicable) to resolve the matter.
• If you agree with the SCDOR’s findings from the original Proposed Assessment:
  • You will not be issued a new Proposed Assessment.
  • Take the actions listed on the original Proposed Assessment (such as paying any tax due, if applicable) to resolve the matter.
• If you and the SCDOR division representative still disagree about the findings of your original Proposed Assessment, the SCDOR division representative will forward your protest to the SCDOR Appeals Section.

Step 4 – The SCDOR Appeals Section will review your protest.

If you and the SCDOR division representative still disagree about the SCDOR’s findings, a representative of the SCDOR Appeals Section will conduct a substantive review of your protest.

The SCDOR Appeals Section representative will offer you an opportunity to discuss your protest. If you reach this point in the appeals process, it is strongly recommended that you meet with the Appeals Section representative.

• The meeting can take place in-person at an SCDOR office or, if both parties agree, the meeting may be held over the phone.
• Both parties will discuss the matter, agree on a stipulation of facts, and attempt to settle the matter during the meeting.

The SCDOR Appeals Section will conduct a full review of your protest.

• If the SCDOR Appeals Section agrees with your position, they will inform you that the matter has been resolved.
• If the SCDOR Appeals Section disagrees with your position, they will forward your protest to the SCDOR Litigation Section.
• The SCDOR Appeals Section may attempt to negotiate a settlement with you.

Step 5 – The SCDOR Litigation Section will review your protest.

If you and the SCDOR Appeals Section still disagree about the SCDOR’s findings, a representative of the SCDOR Litigation Section will conduct a full review of your protest.

An SCDOR Litigation Section representative may offer you an opportunity to discuss your protest.

• The discussion can take place in-person at an SCDOR office or, it may be held over the phone.
• Both parties will discuss the matter during the discussion with the goal of settling the matter.
• After the meeting, the SCDOR Litigation Section will conduct a full review of your protest.

Step 6 – The SCDOR Litigation Section will issue a Department Determination.

After their full review of your protest, the SCDOR Litigation Section will issue a Department Determination. The SCDOR is required by law to issue the Department Determination within one year of your initial protest. 

The Department Determination will clearly state: 

• What both parties agree about
• What both parties disagree about
• Any settlement that was reached during your meeting with the Litigation Section
• The basis for the Litigation Section’s decisions
• The amount of tax, penalties, and interest due, if applicable 

If you still disagree with the findings of the Department Determination, you have the right to request a Contested Case Hearing with the South Carolina Administrative Law Court.

• You have 30 days after your Department Determination is issued to request a Contested Case Hearing.
• Any taxes assessed by the Department Determination are due within 30 days unless you request a Contested Case Hearing.

Step 7 – You will request a Contested Case Hearing.

If you still disagree with the findings of the Department Determination, you have the right to request a Contested Case Hearing with the South Carolina Administrative Law Court.

You have 30 days after your Department Determination is issued to request a Contested Case Hearing.

According to Rule 11 of the Administrative Law Court, your Request for Contested Case Hearing may be on a form prescribed by the Court, and must include:

• The name of the party requesting the hearing and their reasons for requesting it
• A copy of the Department Determination that is the subject of the hearing
• The relief requested

Your request and filing fee must be sent to the Administrative Law Court:
Administrative Law Court
Attn: Clerk of Court
Edgar Brown Bldg., Room 224
1205 Pendleton St
Columbia, SC 29211-1667

You must also send a copy of your request to:
South Carolina Department of Revenue
Office of General Counsel
Attn: [attorney handling case]
300A Outlet Pointe Boulevard
Columbia, SC 29210

For more information on the tax appeals process, see SC Revenue Procedure #20-1.

Step 1 – The SCDOR will issue you a notice.

If you have an unresolved regulatory matter with the SCDOR, we will send you a written notice.

Notices regarding unresolved regulatory matters are called Regulatory Notices. Your Regulatory Notice may have a different title depending on the regulatory matter that needs to be resolved and the SCDOR division issuing the notice. 

Common titles include (but are not limited to):

• Notice of Intent to Revoke
• Notice of Intent to Suspend
• Notice of Intent to Cancel
• Violation Regulatory Notice
• Denial Letter
• Notice of Action on License
• Violation Proposed Assessment

Your Regulatory Notice will clearly state:

• The matters which need to be resolved, including the amount of tax, penalties, and interest due, if applicable
• The basis of the SCDOR’s findings
• The actions you must take to resolve the matter with the SCDOR
• The penalties you will face if you don’t resolve the matter in a timely fashion
• Information you need to file a protest, including where to send your protest, and your rights under the Taxpayers' Bill of Rights.

If you agree with the SCDOR’s findings, take the actions listed on the Regulatory Notice (such as paying any tax or penalties due, if applicable) to resolve the matter. You can avoid further penalties, including tax liens, or the cancellation, suspension, or revocation of your license by resolving the matter by the deadline stated on your Regulatory Notice.

If you do not agree with the SCDOR’s findings, you must file a written protest with the SCDOR within 90 days of the date listed on your Regulatory Notice.

Step 2 – You will file a protest with the SCDOR.

Deadline

If you disagree with the SCDOR’s findings on your Regulatory Notice, you have 90 days to file a written protest.

If the 90th day of the protest period falls on a weekend or state holiday, your deadline will be extended to the next business day.

If the SCDOR receives your written protest within 90 days of your notice, we will not attempt to issue, cancel, suspend or revoke your regulatory license, impose penalties, or take other action until the protest is resolved or a decision has been rendered by the Administrative Law Court.

If you fail to file your written protest for an unresolved regulatory matter within 90 days, the SCDOR will begin the process of denying, canceling, suspending, or revoking your regulatory license and imposing any monetary penalties that have been proposed.

If your business is currently selling beer, wine, or alcoholic liquors under a 120-day temporary license, your license will expire at the end of the 120-day period regardless of whether or not the denial of your biennial alcoholic beverage license has been fully resolved or you have requested a Contested Case Hearing.

How to file your protest

There are three ways to file your protest with the SCDOR: online, with a C-245 form, or in writing without a C-245 form. 

Submit a protest online:

The quickest, easiest way to file a protest is by completing the Protest Pursuant to Revenue Procedures Act (C-245) using our free online tax portal, MyDORWAY.

To submit a protest online, you will need a MyDORWAY account.

1. Log in to MyDORWAY.
2. Select the Accounts tab, then scroll to the account in question.
3. Select More Account Options.
4. On the next screen, click File an Application for Appeal.

If you use MyDORWAY to file your appeal, you are required to attach or mail in a copy of the notice you received related to the appeal. We recommend scanning a copy of your notice before logging in to MyDORWAY so you can attach the copy before completing the application.

File a paper copy of the C-245:

• Download and complete the C-245.
• Send your completed form to the address or email address listed on your Regulatory Notice. You can also hand deliver it to one of our offices. 

File a written protest without using the C-245:

If you choose not to use the C-245, your protest must still contain all of the information on the C-245, including:

• Your name, mailing address, and telephone number
• Your appropriate taxpayer identification number (such as your Social Security Number, License Number, or File Number)
• The tax period or date covered in the Proposed Assessment
• The regulatory matter or license in dispute
• A statement outlining the reasons for your protest, including any law or authority you are basing your protest on
• Any other relevant information
• A copy of the Regulatory Notice you are protesting

Step 3 – The SCDOR Litigation Section will review your protest.

When we receive your protest, the SCDOR Litigation Section will conduct a full review of your protest.

As part of the review process, you may request a discussion with the SCDOR Litigation Section representative.

• The discussion can take place in-person or over the phone.
• Both parties will discuss the matter with the goal of resolving it.

Step 4 – The SCDOR Litigation Section issues a Department Determination.

If there is no resolution after the SCDOR Litigation Section conducts its review of your protest, the Litigation Section will issue a Department Determination.

The SCDOR is required by law to issue the Department Determination within one year of your initial protest.

The Department Determination may include:

• What both parties agree about
• What both parties disagree about
• Any partial resolution that was reached during your discussion with the Litigation Section, if applicable.
• The basis for the Litigation Section’s decisions
• Whether your regulatory license has been issued, denied, cancelled, suspended, or revoked.
• The final determination of any regulatory violations, and any monetary penalty imposed because of the violations.

If you still disagree with the findings of the Department Determination, you have the right to request a Contested Case Hearing with the South Carolina Administrative Law Court.

• You have 30 days after your Department Determination is issued to request a Contested Case Hearing.
• Any taxes assessed by the Department Determination are due within 30 days unless you request a Contested Case Hearing.

Step 5 – You will request a Contested Case Hearing.

If you still disagree with the findings of the Department Determination, you have the right to request a Contested Case Hearing with the South Carolina Administrative Law Court. You have 30 days after your Department Determination is issued to request a Contested Case Hearing.

According to Rule 11 of the Administrative Law Court, your Request for Contested Case Hearing may be on a form prescribed by the Court, and must include the following information:

• The name of the party requesting the hearing and their reasons for requesting it
• A copy of the Department Determination that is the subject of the hearing
• The relief requested

Your request and $100 filing fee must be sent to the Administrative Law Court:
Administrative Law Court
Attn: Clerk of Court
Edgar Brown Bldg., Room 224
1205 Pendleton St
Columbia, SC 29211-1667

You must also send a copy of your request to:
South Carolina Department of Revenue
Office of General Counsel
Attn: [attorney handling case]
300A Outlet Pointe Boulevard
Columbia, SC 29210

For more information on the regulatory appeals process, see SC Revenue Procedure #20-3.

Any person who meets the requirements of South Carolina Regulation 7-201 may protest the SCDOR’s issuance or renewal of an Alcohol Beverage License. The person must:

• Reside in the county where the ABL license is requested to be granted, OR
• Reside within five miles of the location where the ABL license is requested to be granted.

To file a third-party protest:

• Law enforcement agencies must submit the Notice of Application/Law Enforcement Protest (ABL-10).
• All other residents must submit the Beer, Wine, and/or Liquor Protest Form (ABL-20).

Both forms are available at dor.sc.gov/forms.

You can submit the ABL-10 or ABL-20 by:

• Mailing it to SCDOR, ABL Section, PO Box 125, Columbia, SC 29214-0907
• Faxing it to 803-896-0110
• Emailing it to abl@dor.sc.gov

Your ABL-10 or ABL-20 must be postmarked or received by the SCDOR no later than 15 days from the date the proposed location was posted by SLED or the date to protest as sworn in the Notice of Advertisement in the newspaper, whichever is later.

If you file a third-party protest, you are required to attend a Contested Case Hearing before the Administrative Law Court and offer testimony on why the location should not be issued an ABL license. Your protest will be denied if you do not attend a Contested Case Hearing.

If the third party’s protest meets all statutory requirements, we will issue a Regulatory Notice denying the license or renewal to the ABL license holder/applicant. If the ABL license holder/applicant wants to continue pursuing the license or renewal, they must appeal the decision by following the regulatory appeals process (see above).