A-Fab Eng'g v. Prop. Tax Div. of the Utah State Tax Comm'n

MORTENSEN, Judge:

¶1 "[I]n this world nothing can be said to be certain, except death and taxes." 1 Nearly as certain is the procedural bar attendant to court challenges when a party has failed to exhaust administrative remedies, resulting in an absence of jurisdiction. A-Fab Engineering (A-Fab) challenges two property tax assessments levied in 2012 and 2013 by the Utah State Tax Commission (Commission). The Commission dismissed A-Fab's administrative appeal as untimely. A-Fab then petitioned the district court for review of the Commission's decision. The district court summarily dismissed the…