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MIDAN LTD. v. DISTRICT OF COLUMBIA

No. 95-TX-1681.

692 A.2d 1340 (1997)

MIDAN LIMITED PARTNERSHIP, Appellant, v. DISTRICT OF COLUMBIA, Appellee.

District of Columbia Court of Appeals.

Decided January 31, 1997.

Attorney(s) appearing for the Case

Harold Gordon, with whom Robert D. Roadman was on the brief, Warrenton, VA, for appellant.

Martin B. White, Assistant Corporation Counsel, with whom Charles F.C. Ruff, Corporation Counsel at the time, and Charles L. Reischel, Deputy Corporation Counsel, were on the Memorandum in Lieu of Brief, for appellee.

Before FERREN, FARRELL, and REID, Associate Judges.

PER CURIAM.

This appeal from the grant of a motion to dismiss on Super.Ct.Civ.R. 12(b)(6) grounds1 contests an apparent policy or practice by the District government during the tax year 1994 to give written notice regarding the potentially premature filing of tax assessment challenges to some filers but not others. Appellant makes strictly a constitutional argument, contending that the disparate notification of some taxpayers but not others...

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