Philip L. Hart v. Idaho State Tax Commission

J. JONES, Justice.

This case involves Philip L. Hart’s appeal of an Idaho Board of Tax Appeals (BTA) decision. Hart appealed two State Tax Commission Notice of Deficiency determinations to the BTA. The BTA found Hart’s appeal untimely and therefore dismissed it. Hart appealed to the district court, which likewise found his BTA appeal untimely and dismissed for lack of jurisdiction. We affirm the district court.

I

BACKGROUND

The State Tax Commission (Commission) issued Hart two Notice of Deficiency (NOD) .determinations on September 4, 2008. One NOD covered tax years 1996 through 1998 and the…