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CASTELLANO v. KOSYDAR

No. 74-370.

42 Ohio St. 2d 107 (1975)

CASTELLANO ET AL., APPELLANTS, v. KOSYDAR, TAX COMMR., APPELLEE.

Supreme Court of Ohio.

Decided April 16, 1975.

Attorney(s) appearing for the Case

Messrs. Mancino, Mancino & Mancino and Mr. Paul Mancino, Jr., for appellants.

Mr. William J. Brown, attorney general, and Mr. John C. Duffy, Jr., for appellee.

HERBERT, J.

This appeal presents the question of whether the period of time for filing a petition for reassessment, pursuant to R. C. 5739.13, begins to run when service of the notice of assessment is effectuated, or from the date the taxpayer receives actual notice of such assessment.

R. C. 5739.13 provides, in pertinent part:

"In each case the commissioner shall give to the person assessed written notice of such assessment. Such notice may be served...

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