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DISTRICT OF COLUMBIA v. WILLARD ASSOCIATES

No. 93-TX-1123.

655 A.2d 1237 (1995)

DISTRICT OF COLUMBIA, Appellant, v. WILLARD ASSOCIATES, Appellee.

District of Columbia Court of Appeals.

Decided March 20, 1995.

Attorney(s) appearing for the Case

Lutz Alexander Prager, Asst. Deputy Corp. Counsel, Washington, DC, with whom Vanessa Ruiz, Acting Corp. Counsel at the time, and Charles L. Reischel, Deputy Corp. Counsel, were on the brief, for appellant.

Stanley J. Fineman, with whom Louis P. Robbins and David A. Fuss, Washington, DC, were on the brief, for appellee.

Before FARRELL and KING, Associate Judges, and KERN, Senior Judge.

FARRELL, Associate Judge:

For the tax year 1990, appellee Willard Associates ("Willard") failed to submit in timely fashion information required annually by the Mayor of the District of Columbia to assist in the apportionment of "mixed use" property for purposes of real property taxation. A regulation adopted by the Mayor through the Department of Finance and Revenue (the "Department") provided that in the event this information was not submitted in time, "the Director...

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