OPINION
FIDEL, Judge.
In this novel proceeding, plaintiffs and defendants jointly petition this court to set aside the tax court's dismissal of the underlying tax appeal. Although plaintiffs and defendants dispute the merits of the underlying action, they jointly challenge the tax court's ruling that plaintiffs' action was not timely filed. The parties argue that the tax court misinterpreted the applicable statutes and ask us to reinstate the action for resolution...
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