Target Corp. v. Jefferson County Board of Equalization

Target Corporation (“Target”) contends that its appeal to the Jefferson Circuit Court (“the trial court”) of ad valorem tax assessments made by the Jefferson County Board of Equalization (“the Board”) was properly perfected pursuant to the Alabama Administrative Procedure Act (“the AAPA”), § 41-22-1 et seq., Ala.Code 1975, and, therefore, was not subject to dismissal. The Board contends that the AAPA does not apply to Target’s appeal, that the procedure set out in § 40-3-25, Ala.Code 1975, is the only procedure for taking such an appeal, and that Target’s failure to comply with that statute…