Zeigler Coal Co. v. Commonwealth, Department of Revenue

COMBS, Judge.

Taxpayer seeks reversal of a judgment of the Franklin Circuit Court which held that the Department of Revenue tax assessment is final, due and owing.

After taxpayer received notice of a tax lien placed on its Kentucky property, it sought administrative review of the assessment. The Department refused to review the assessment because no protest was filed within 30 days following the notice of tax assessment. See KRS 131.110(1).

Taxpayer argues that both the assessment and the lien are void because it did not receive the KRS 131.110(1) notice of assessment. The Department relies upon…