In 2025 the Comptroller published a number of sales tax documents in STARS.
In real terms, there were 146 documents published which consisted of:
101 Hearings
17 Private Letters
9 Web content updates
2 Memos
8 Publication & Statute Updates
1 Rule Update
Which was fairly close to 2024's 147 documents.
What I found particularly interesting is how the indexing of these items shook out in 2025 compared to 2024.
Whenever a new document is published to STARS, it's also given an index category, so similar issues can be more readily groups and reviewed, with the one except of "INDEXED BY TAX TYPE ONLY" which means, in plain terms, a hearing was held and nothing happened. No one showed up, no documents were presented, but a hearing was held regardless.
38 of the 101 Hearings sales and use tax hearings are this category. Nearly 38% of all hearings done last year had no substance.
Now you may think that's high but in 2024 there were 102 hearings, 46 of which were indexed by tax type only, or about 45%.
I think one of the easiest conclusions to reach is the Comptroller is more than happy to take an unprepared and unrepresented protesting taxpayer through
hearings.
We may be seeing the result of more taxpayers using the 'hearings bypass' process, though by my recollection, many of these were cstore/liquor stores, which in general tend not to be worth a district court fight.
I also published this on linkedin, that would be the most appropriate place to provide comments.
