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Property Tax Classification Appeals

October 16, 2019

Property Tax Classification Appeals

Case:   East Tennessee Pilot’s Club, Inc. v. Knox County Tennessee, Et Al.

Facts:   After an ALJ concluded certain property should be classified as “farm property,” the county property assessor reclassified it in 2013 as split property, commercial and farm. The property owner paid its 2013 to 2016 taxes “under protest” and filed suit seeking a refund under TCA 67-5-901, arguing the chancery court had jurisdiction because purely legal issues were involved and the doctrines of res judicata and/or collateral estoppel prevented such reclassification. Upon determining that it lacked subject matter jurisdiction, the trial court granted the government’s motion to dismiss.

Appellate Decision:   The intermediate court affirmed the dismissal, holding that the property owner’s remedy was to appeal the assessment to the county board of equalization. See Tenn. Code Ann. § 67-5-1401.

Review Granted:   June 19, 2019.

Prediction:   Ben thinks the Supreme Court affirm the dismissal for the reasons provided by the intermediate court.