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HART v. IDAHO STATE TAX COM'N

No. 38756.

301 P.3d 627 (2012)

Philip L. HART, Petitioner-Appellant, v. IDAHO STATE TAX COMMISSION and Idaho Board of Tax Appeals, Respondents.

Supreme Court of Idaho, Boise, April 2012 Term.

Rehearing Denied June 7, 2012.

Attorney(s) appearing for the Case

Starr Kelso , Coeur d'Alene, argued for appellant.

Hon. Lawrence G. Wasden , Attorney General, Boise, for respondents. William A. Von Tagen argued.

J. JONES, Justice.

This case involves Philip L. Hart's appeal of an Idaho Board of Tax Appeals (BTA) decision. Hart appealed two State Tax Commission Notice of Deficiency determinations to the BTA. The BTA found Hart's appeal untimely and therefore dismissed it. Hart appealed to the district court, which likewise found his BTA appeal untimely and dismissed for lack of jurisdiction. We affirm the district court.

I.

BACKGROUND

The State Tax...

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