The Oklahoma Bar Journal October 2026

before seeking administrative relief of any kind. OTC processes and rules are not necessarily applicable to other agencies, and not even things as simple as definitions are promised to be identical. For instance, the OTC and IRS sometimes use different terminology when referring to tax disputes. The OTC does not use the term “appeals” or “medi ation” and does not acknowl edge “offers in compromise.” Therefore, it is crucial that before a taxpayer seeks administrative relief through the OTC or another agency, the taxpayer should refer ence the relevant rules and proce dures. Oftentimes, the OTC will immediately deny applications for relief that are not submitted in accordance with state law. 25 Another reason to be familiar with OTC administrative relief is that taxpayers must typically exhaust all administrative reme dies before appealing to a different court. 26 This means that if the OTC brings a civil lawsuit in district court against a taxpayer, the tax payer cannot argue the validity of the liability in district court. While nobody wants to seek out conflict, issues do arise. Everyone is better off – the state, the aggrieved taxpayer, and the general Oklahoma population – when all parties are well advised of the pertinent rules and laws. Accordingly, make sure you, your friends and family, and your clients have access to this information for when they may need it.

ABOUT THE AUTHOR

Marina Wise is an assistant general counsel

at the Oklahoma Tax Commission’s Tulsa office. Ms. Wise was born in Brownsville, Texas, and earned her bachelor’s degree from Austin College before graduating from the TU College of Law in 2021. Her practice is centered on business tax compliance and collection, as well as bankruptcy. She covers cases in all Oklahoma district courts as well as the bankruptcy courts for Oklahoma’s Northern and Eastern districts. ENDNOTES 1. Lil Wayne, “Right Above It,” (Young Money Entertainment; Cash Money Records; Universal Motown, 2010). 2. See generally 68 O.S. §§101 et seq. 3. See generally Okla Admin Code §§1-1-2 et seq. 4. This article may be used as an informational reference but is not an exhaustive list of administrative processes and remedies. 5. See 68 O.S. §221. 6. See generally 68 O.S. §228; see generally 710:1-5-10, 13, 24, 25(7). 7. See 68 O.S. §205.2. 8. “Form L-21 Request for Innocent Spouse Relief Information”, Oklahoma Tax Commission, https://bit.ly/4iDizJp 9. “Oklahoma Parental Choice Tax Credit Program,” Oklahoma Tax Commission, https://bit.ly/4y8RmmR. 10. See 710:1-5-100. 11. See 710:1-3-80. 12. See generally 710:1-3-70. 13. See 51 O.S. §24a.2. 14. See 68 O.S. §220; 710:1-5-12. 15. Oklahoma Tax Commission OkTAP, 16. See 68 O.S. §221(C). 17. See id . 18. See 68 O.S. §221, 226. 19. See 68 O.S. §219.1; 710:1-5-70 et seq. 20. See 68 O.S. §219; 710:1-5-13. 21. “Oklahoma Parental Choice Tax Credit Program,” Oklahoma Tax Commission, https://bit.ly/4yJ1oee. 22.23 “Application for Commission Hearing”, Oklahoma Tax Commission, https://bit.ly/46HTK7V. 23. “Letter Rulings,” State of Oklahoma Tax Commission, https://bit.ly/47acZqP. 24. “General Contact,” Oklahoma Tax Commission, https://bit.ly/4y4h8Zb. 25. See 710:1-5-46. 26. See 710: 1-5-40(9). https://bit.ly/4AoeS0F .

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

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THE OKLAHOMA BAR JOURNAL