Franklin County Realty Trust v. Board of Assessors

The taxpayer concedes that it did not, within statutory time limits, file appeals with the Appellate Tax Board (board) from the denial, by inaction of the board of assessors (assessors), of the taxpayer’s applications for abatement of local real estate taxes. G. L. c. 59, §§ 64, 65, 65C. The taxpayer argues that because the assessors continued to consider its applications after the expiration of the appeal periods, the assessors should be estopped to deny the timeliness of the taxpayer’s appeals to the board.

Generally we have not looked with favor on contentions that public officials are…