WAGNER, Chief Judge:
Appellant, Friendship Hospital for Animals, Inc., (FHA), appeals from an order of the trial court granting the motion of appellee, the District of Columbia (District), to dismiss as untimely FHA's petition for review of the District's denial of its claim for a refund of corporate franchise taxes. The trial court's decision was premised upon the fact that FHA's claim was the subject of a deficiency assessment proceeding resolved against FHA, but...
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