Cost Management Services, Inc. v. City of Lakewood

¶1 For many years, Cost Management Services Inc. (CMS) made a certain tax payment to the city of Lakewood. In late 2008, upon examining the relevant regulations, CMS decided that it did not in fact owe the tax that it had been paying. In October 2008, it stopped paying the tax, and in November 2008, it submitted a claim to Lakewood for a refund of taxes it had previously paid from 2004 to September 2008.

¶2 Lakewood did not respond to the request for a refund of the 2004-2008 tax payments. But six months later, in May 2009, it issued a notice and order to CMS demanding payment of past due…