New Garden Restaurant, Inc. v. Director of Revenue

New Garden Restaurant, Inc. petitions for review of the Administrative Hearing Commission’s summary decision dismissing New Garden’s appeal of the Director of Revenue’s tax assessments against New Garden. The Commission held it had no .authority to hear New Garden’s appeal because the appeal was nof filed within the time limitation for doing so. New Garden argues the Commission’s interpretation of §§ 621.050.1 and 144.261 1 is unfair to taxpayers and violates the due process clauses of the Missouri and United States constitutions. 2 New Garden also argues the Commission erred in: (1) holding…