Taxpayer Argues Missed Appeal Deadline Should be Waived Because Tax Commissioner Sent Wrong Filing Instructions

Seeks Reversal Of Order Denying Reassessment Based on Missed Filing Deadline

Crown Communication, Inc./Crown Castle GT Company, LLC v. Richard A. Levin [Joseph W. Testa], Tax Commissioner of Ohio, Case no. 2012-0780

Appeal from order of State Board of Tax Appeals

ISSUE: When the State Tax Commissioner provides a property owner with incorrect instructions for filing an appeal of the commissioner's final assessment of the owner's property, and the taxpayer timely complies with the commissioner's erroneous instructions, does the commissioner's error toll (stop the running of) the statutory time limit within which the taxpayer must file its notice of appeal with the Board of Tax Appeals until the taxpayer is provided with correct filing instructions?