Lee v. Chilivis

Nichols, Chief Justice.

After an official notice of assessment and demand for payment for past-due sales tax, deliquency penalty and interest was issued by the State Revenue Commissioner against Robert Harry Lee and Mildred Lee, they filed an appeal to the Fulton County Superior Court. Thereafter, the State Revenue Commissioner filed a motion to dismiss such appeal upon the grounds that (1) "the Court lacks jurisdiction over the subject matter” and (2) "because Appellants have failed to satisfy the jurisdictional prerequisites for maintaining this appeal.”

In support of the motion to dismiss…