Gibson v. Levin

{¶ 1} Appellants, James E. Gibson and Verna K. Gibson, contest an assessment of unpaid personal income tax issued against them on February 3, 2006. They initiated the present proceedings by filing a petition for reassessment on April 3, 2006.

{¶ 2} Under certain circumstances, income tax payers who file a petition for reassessment must pay the assessment, including interest, to have their petition heard. One such circumstance is when the taxpayers have not filed the required returns before the assessment is issued, R.C. 5747.13(E)(2), which is what the *518Tax Commissioner contends happened here —…