Luchini v. Commissioner of Revenue

Charles and Billie K. Luchini (Luchinis) dispute their income tax bill, and claim that the lien recorded by the Department of Revenue (department) to recover the money is invalid because it attached to property that they did not own at the time the lien was created. Because we agree with the Superior Court judge’s conclusions that (1) the Luchinis waived their right to appeal the assessments’ validity by failing to exhaust their administrative remedies, and (2) tax liens may attach to after-acquired property, we affirm.

1. Facts. The Luchinis lived abroad from 1980 through 1988. Believing…