Cruz v. Testa (Slip Opinion)

{¶ 1} In this appeal, appellant, Susan C. Cruz, contests 27 assessments of delinquent sales tax that, when added to preassessment interest, penalties, and additional charges, amounted to over $599,000. Cruz’s liability derives from previous assessments issued against Cruz-Samsa Corporation, a pet-store business of which Cruz was co-owner and an officer. We confront a jurisdictional issue and an issue on the merits.

{¶ 2} With regard to the jurisdictional issue, appellee, the tax commissioner, argues that this appeal must be dismissed on the grounds that Cruz failed to set forth an error, as…