Sorg Paper Co. v. Limbach

William W. Young, Judge.

In April 1987, appellant, Sorg Paper Company (“Sorg”), filed amended returns for its 1985 and 1986 personal property tax returns. In submitting its application for a refund, Sorg argued that it had used the historical book value for determining the value of its personal property during the 1985 and 1986 tax years instead of the new book value. Thus, the request for a refund was based solely upon computing the alleged true value of its machinery and equipment using the new book value rather than the historical book value.

Upon an audit of Sorg’s 1985 and 1986 personal…