OPINION
SCHAFER, Judge.
The parties raise two issues in this case. One is whether the Assessor may audit prior years' personal property tax returns and retroactively impose taxes found unpaid. The other is whether taxes are "delinquent" when a corrected tax bill is mailed out after settlement with a stated delinquency date prior to the date of mailing. But the Court will not decide either issue because of the untimeliness of the appeal.
In the fall...
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