State v. Petro-Lewis Corp.

HOLMES, Judge.

This is a tax case.

Following an adverse ruling at the administrative level, the State of Alabama Department of Revenue (Department) appealed to the Montgomery County Circuit Court. The circuit court granted the taxpayer’s motion to dismiss on the grounds that the circuit court lacked jurisdiction because the Department’s appeal was untimely.

The Department appeals and we affirm.

The record reveals that the taxpayer requested an administrative hearing to dispute the Department’s initial assessment. Following the hearing, an administrative law judge (AU) entered an order in the…