District of Columbia v. Willard Associates

FARRELL, Associate Judge:

For the tax year 1990, appellee Willard Associates (“Willard”) failed to submit in timely fashion information required annually by the Mayor of the District of Columbia to assist in the apportionment of “mixed use” property for purposes of real property taxation. A regulation adopted by the Mayor through the Department of Finance and Revenue (the “Department”) provided that in the event this information was not submitted in time, “the Director [of the Department] shall classify the affected taxpayer’s real property as Class Four Property for the next taxable year.” 9…