32 V.S.A. § 10109: Determination by Commissioner

(a) Upon receipt of a notice of deficiency or assessment of penalty or interest under section 10106 of this title or upon receipt of a notice of the denial of all or a portion of a refund request under section 10107 of this title, the taxpayer may, within 60 days after the date of mailing of the notice or assessment, petition the Commissioner in writing for a determination of that deficiency or assessment. The Commissioner shall thereafter grant a hearing upon the matter and notify the taxpayer in writing of the Commissioner’s determination concerning the deficiency, assessment, or refund request.

(b) The aggrieved taxpayer may, within 30 days after a determination by the Commissioner concerning a notice of deficiency, an assessment of penalty or interest, or a claim to refund, appeal that determination to the Washington Superior Court or the Superior Court of the county in which the taxpayer resides or has a place of business.