OPINION
PAGE, Justice.
This case raises the question of whether the tax court has jurisdiction to hear relator Henry J. Langer's appeal from an order of the Commissioner of Revenue (Commissioner) assessing Langer and his wife, Patricia K. Langer, for unpaid income taxes, interest, and penalties for tax years 2003, 2004, 2005, and 2006. Finding that the Langers' appeal was untimely, the tax court dismissed the appeal for lack of subject matter jurisdiction...
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