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FIRST INTERSTATE v. DISTRICT OF COLUMBIA

No. 90-551.

604 A.2d 10 (1992)

FIRST INTERSTATE CREDIT ALLIANCE, INC., Appellant, v. DISTRICT OF COLUMBIA, Appellee.

District of Columbia Court of Appeals.

Decided March 3, 1992.

Attorney(s) appearing for the Case

C. Francis Murphy, Washington, D.C., for appellant.

Lutz Alexander Prager, Asst. Deputy Corp. Counsel, with whom John Payton, Corp. Counsel, and Charles L. Reischel, Deputy Corp. Counsel, Washington, D.C., were on the brief, for appellee.

Before TERRY, STEADMAN, and SCHWELB, Associate Judges.

TERRY, Associate Judge:

This appeal presents a question of first impression regarding the interpretation of D.C.Code § 47-3303 (1990). We read that statute, along with D.C.Code § 47-453 (1990), as imposing upon the taxpayer an obligation to pay all taxes due, together with interest accruing until the time of payment, before filing in the Superior Court a petition challenging a notice of tax deficiency. Because appellant did not do that, we affirm the trial...

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