State of Vermont, Department of Taxes v. Kenneth C. Montani/Thomas A. Tatro/Tyre Duvernay/Thomas L. Marchant

¶ 1. The Vermont Department of Taxes appeals from trial court orders in favor of defendants in these consolidated tax-collection cases. The court concluded that the underlying tax debts were invalid because the Department issued its notices of deficiencies or assessments of penalty or interest to defendants more than three years after defendants' tax returns were originally due. The Department argues that the court lacked subject matter jurisdiction to consider the validity of the underlying debts in these collection actions, and that, in any event, it erred in concluding that a three-year…