City of Union City v. Ormond Tool & Manufacturing Co.

The opinion of the Court was delivered

Pee Ctxbiasc.

The City of Union City appealed from judgments of the Division of Tax Appeals relating to the assessment of property for the years 1954 and 1955. We certified the appeals on our own motion prior to consideration of them by the Appellate Division.

The taxpayer prevailed before the county board, and both parties appealed to the Division. The taxpayer’s petitions of appeal to the county board and to the Division did not raise the issue of discrimination. The Division, however, entertained the question on the thesis that it could be urged in…