Can Massachusetts deny an innocent spouse claim for someone granted federal innocent spouse for the same tax year/income?

My mother was granted innocent spouse relief by the federal government for tax years where she had no knowledge of gambling winnings or 401k withdrawals that my father made and left off their joint tax return. At the time she signed the tax return, she believed the income reported to be correct. She found out later, after they divorced, that my father had hid this income when the federal and state government of Massachusetts came after her for back taxes. (They "cannot locate" my father.) Massachusetts has denied her request for the same tax year and circumstances for which the federal government has already given her relief. They are requesting $65 to consider an appeal (which she can't afford) or else are attaching her wages (also can't afford). Do we have any further recourse?