In Re the Appeal of Sumner County

The opinion of the court was delivered by

Lockett, J.:

Boeing Military Airplanes (Boeing) seeks review of the Court of Appeals’ application of the doctrine of “unique cir*308cumstances” to excuse Sumner County’s (the County) untimely filed petition for reconsideration of an order of the Board of Tax Appeals (BOTA). The County failed to file the petition for reconsideration within 15 days after service of the BOTA order as required by statute. The “unique circumstances” found by the Court of Appeals derives from a statement in BOTA’s original order that its regulation allowed the County 30 days…