Crown Communication, Inc. v. Testa

{¶ 1} Crown Communication, Inc., and Crown Castle GT Company (collectively, “Crown”) appeal from a decision of the Board of Tax Appeals (“BTA”) that affirmed the tax commissioner’s final determination of a personal-property tax assessment for tax year 2006. The tax commissioner and the BTA both held that Crown had not timely pursued an appeal from final-assessment certificates previously issued by the tax commissioner. Under this determination, the commissioner lacked jurisdiction to reach the merits of Crown’s petition for reassessment and the BTA lacked jurisdiction to reach the merits of…