Overstreet v. Colorado Department of Revenue

Opinion by

Judge FURMAN.

S. Dianne Overstreet (Taxpayer) appeals the district court’s order dismissing her appeal from a final determination by the executive director of the Colorado Department of Revenue (Department) because she failed to comply with the mandatory bond provisions of section 39-21-105, C.R.S.2007. We affirm.

I. Background

After Taxpayer and her husband dissolved their marriage and divided corporate stock held in the husband’s name, Taxpayer realized a capital gain of $4,218,000 from the sale of her shares of the stock. In filing her 1999, 2000, and 2001 Colorado income tax…