STATE OF NEVADA

BEFORE THE [NEVADA TAX TRIBUNAL / NEVADA TAX COMMISSION]*

PETITION FOR REVIEW AND REDETERMINATION OF STATE TAX ASSESSMENT

(select correct tribunal depending on tax type and amount)

[// GUIDANCE: This template is designed for use in appealing a final tax assessment issued by the Nevada Department of Taxation (“NDOT”). It may also be adapted for property-tax or other specialty tribunals, provided the practitioner verifies procedural variances.]

TABLE OF CONTENTS

1. Document Header
2. Definitions
3. Operative Provisions
   3.1 Filing & Jurisdiction
   3.2 Scope of Review
   3.3 Burden of Proof
   3.4 Collection Stay Request
   3.5 Evidentiary Requirements
   3.6 Hearing Procedures
4. Representations & Warranties
5. Covenants & Restrictions
6. Default & Remedies
7. Risk Allocation
8. Dispute Resolution
9. General Provisions
10. Execution Block

1. DOCUMENT HEADER

1.1 Parties.
This Petition (“Petition”) is submitted by [PETITIONER LEGAL NAME], a [state] [entity type] having its principal place of business at [ADDRESS] and Nevada Taxpayer I.D. No. [TIN] (“Petitioner”), against the NEVADA DEPARTMENT OF TAXATION (“Respondent”).

1.2 Effective Date.
This Petition is deemed filed on [DATE STAMPED BY TRIBUNAL] (“Effective Date”).

1.3 Jurisdiction & Venue.
This matter is governed by applicable Nevada revenue and taxation statutes and regulations (“Applicable Law”) and is properly before the [TRIBUNAL] pursuant to the final assessment determination dated [DATE OF FINAL ASSESSMENT] (“Assessment”).

1.4 Consideration.
Petitioner seeks review and redetermination of the Assessment and, if warranted, refunds or abatements, together with statutory interest.

2. DEFINITIONS

For purposes of this Petition, the following terms have the meanings set forth below. Capitalized terms used but not defined herein have the meanings ascribed in Applicable Law.

“Administrative Record” – All documents, data, and other materials relied upon by NDOT in issuing the Assessment and any supplementary materials admitted into evidence in this Proceeding.

“Assessment” – The final notice of tax liability, including penalties and interest, issued by NDOT to Petitioner on [DATE].

“Burden of Proof” – The obligation of Petitioner to establish, by a preponderance of the evidence (unless a higher standard is imposed by Applicable Law), that the Assessment is incorrect in whole or in part.

“Collection Stay” – A suspension, pursuant to Applicable Law, of NDOT’s collection activities pending final disposition of this Proceeding.

“Petition” – This Petition for Review and Redetermination, inclusive of all exhibits, schedules, and amendments.

“Proceeding” – All stages of adjudication before the Tribunal relating to this Petition.

“Respondent” – The Nevada Department of Taxation and its authorized agents.

“Tribunal” – The Nevada Tax Tribunal or such administrative body with statutory authority to hear the Petition.

3. OPERATIVE PROVISIONS

3.1 Filing & Jurisdiction

(a) Timeliness. Petitioner affirms that this Petition is filed within the statutory deadline of [XX] days from service of the Assessment.
(b) Service. A copy of this Petition has been served upon NDOT via [CERTIFIED MAIL / E-SERVICE] in compliance with Tribunal rules.

3.2 Scope of Review

The Tribunal is requested to (i) examine the Administrative Record; (ii) consider additional evidence under Section 3.5; and (iii) determine whether the Assessment should be affirmed, modified, or vacated.

3.3 Burden of Proof

Petitioner acknowledges that it bears the Burden of Proof and shall present competent, credible, and admissible evidence demonstrating the Assessment’s factual or legal error(s).

3.4 Collection Stay Request

(a) Stay Election. Pursuant to Applicable Law, Petitioner hereby elects a Collection Stay effective upon either:
(i) full payment of the disputed amount under protest; or
(ii) posting of an acceptable surety bond, letter of credit, or other security in the amount of [DISPUTED TAX + STATUTORY PERCENTAGE]%.
(b) Automatic Termination. The Stay automatically terminates upon (i) final non-appealable resolution adverse to Petitioner, or (ii) Petitioner’s breach of any security or bond condition.

3.5 Evidentiary Requirements

(a) Exhibits. Petitioner shall lodge with the Tribunal and serve Respondent with:
• Exhibit A – Statement of Contested Issues
• Exhibit B – Schedule of Claimed Overpayments/Offsets
• Exhibit C – Supporting Documentation (e.g., invoices, exemption certificates)
(b) Witnesses. Petitioner identifies the following witnesses: [NAME / TITLE / SUBJECT].

[// GUIDANCE: Add or modify exhibits/witnesses as appropriate. Tribunal rules generally require a pre-hearing exchange deadline; calendar accordingly.]

3.6 Hearing Procedures

(a) Appearance. Petitioner will appear through counsel of record, [ATTORNEY NAME, BAR NO.]
(b) Time Allocation. Petitioner requests [HOURS] hours for direct presentation and reserves rebuttal.
(c) Alternative Disposition. Petitioner is amenable to dispositive motion practice or stipulated resolution.

4. REPRESENTATIONS & WARRANTIES

4.1 Authority. Petitioner has full power and authority to file this Petition and pursue the requested relief.

4.2 Accuracy of Information. All factual statements contained herein and in the accompanying exhibits are true, correct, and complete to the best of Petitioner’s knowledge, information, and belief.

4.3 Compliance with Security Requirements. Any bond or deposit provided to secure the Collection Stay is valid, enforceable, and issued by an entity authorized to transact business in Nevada.

4.4 Survival. The representations and warranties herein survive dismissal, withdrawal, or final disposition of the Proceeding.

5. COVENANTS & RESTRICTIONS

5.1 Ongoing Cooperation. Petitioner shall promptly furnish additional records reasonably requested by Respondent or ordered by the Tribunal.

5.2 Notice of Changes. Petitioner shall notify the Tribunal and Respondent within five (5) business days of any material change in contact information, corporate status, or representation.

5.3 Non-Interference. Petitioner shall not impede Respondent’s lawful audit or information-gathering activities unrelated to the Assessment.

6. DEFAULT & REMEDIES

6.1 Events of Default. Each of the following constitutes a default:
(a) Failure to maintain security for the Collection Stay;
(b) Failure to comply with a Tribunal order;
(c) Submission of materially false information.

6.2 Cure Period. Petitioner shall have ten (10) days after written notice to cure any default, unless the Tribunal orders otherwise.

6.3 Remedies. Upon uncured default, Respondent may seek:
(a) Termination of the Collection Stay;
(b) Immediate enforcement of the Assessment;
(c) Costs and attorney fees under Section 6.4.

6.4 Attorney Fees & Costs. If either party prevails on any material claim or defense, the Tribunal may award reasonable attorney fees and costs as authorized by Applicable Law.

7. RISK ALLOCATION

7.1 Indemnification. Petitioner shall indemnify, defend, and hold harmless Respondent from any third-party claims arising out of Petitioner’s intentional misrepresentation or fraudulent conduct in connection with this Proceeding.

7.2 Limitation of Liability. Other than collection of the tax, penalties, and interest lawfully owed, neither party shall be liable for consequential, incidental, or punitive damages.

7.3 Force Majeure. Deadlines may be tolled for the period of any force-majeure event rendering a party unable to perform, provided written notice is given within five (5) days of the event’s onset.

8. DISPUTE RESOLUTION

8.1 Governing Law. This Petition and any related judicial review are governed by the laws of the State of Nevada, without regard to conflict-of-laws principles.

8.2 Forum Selection. Exclusive venue lies with the [TRIBUNAL] and, upon exhaustion of administrative remedies, the Nevada district courts.

8.3 Arbitration (Limited). By mutual written agreement executed after final Tribunal decision, the parties may submit any remaining monetary disputes to binding arbitration under rules agreed upon at that time.

8.4 Jury Waiver. To the extent a right to jury trial exists for any matter arising from this Petition, such right is knowingly and voluntarily waived by all parties.

8.5 Injunctive Relief. Nothing herein limits either party’s right to seek provisional or injunctive relief to enforce Tribunal orders or protect statutory rights.

9. GENERAL PROVISIONS

9.1 Amendments. This Petition may be amended only by written motion granted by the Tribunal.

9.2 Assignment. Neither this Petition nor any related rights may be assigned without Tribunal approval.

9.3 Successors & Assigns. This Petition is binding upon and inures to the benefit of the parties and their permitted successors and assigns.

9.4 Severability. If any provision is deemed unlawful or unenforceable, the remaining provisions continue in full force, and the Tribunal may reform the invalid provision to the minimum extent necessary.

9.5 Integration. This Petition, together with all properly admitted exhibits, constitutes the entire statement of Petitioner’s claims and supersedes all prior submissions on the Assessment.

9.6 Counterparts; Electronic Signatures. This Petition may be executed in counterparts, including electronic counterparts, each of which is deemed an original.

10. EXECUTION BLOCK

IN WITNESS WHEREOF, the undersigned has caused this Petition to be executed on the date set forth below.

Counsel of Record for Petitioner

[ATTORNEY NAME], Esq. – NV Bar No. [XXXX]
[LAW FIRM]
[ADDRESS] • [PHONE] • [EMAIL]

[// GUIDANCE: Attach notary acknowledgment if entity bylaws or Tribunal rules require verification. For property-tax appeals, include statutory verification and certification forms.]

CERTIFICATION
I certify under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief.

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[AUTHORIZED SIGNATORY]
Date: [DATE]

[// GUIDANCE:
1. Double-check Tribunal rules on page limits, margin requirements, and mandatory captions.
2. Confirm filing fees and whether electronic filing is mandatory.
3. Calendar all responsive deadlines immediately upon filing.
4. Consider requesting informal conference or settlement program where available. ]