Kellogg Co. v. Tennessee Assessment Appeals Commission

FARMER, Judge.

Kellogg Company and Kellogg, U.S.A., Inc. (hereinafter collectively “Kellogg”), appeal from the judgment of the trial court dismissing their “petition for judicial review” on the ground that the court lacked subject matter jurisdiction. The petition sought review of the decision of the Tennessee Assessment Appeals Commission and the Tennessee State Board of Equalization (Board) that the Shelby County Assessor 1 had properly assessed certain tangible personal property, identified as “Construction In Process” (CIP), owned by Kellogg on the effective date of January 1, 1993.…