Frontier Chevrolet v. Department of Revenue

¶1 Appellant Frontier Chevrolet Company (Frontier) appeals the order of the Thirteenth Judicial District Court, Yellowstone County, affirming the decision of the Montana State Tax Appeal Board (STAB) requiring Frontier to pay additional taxes and interest thereon for tax years 1995 and 1996. We affirm.

¶2 We restate the issue on appeal as follows:

¶3 Did the District Court err by affirming STAB’s determination that the Department of Revenue’s assessment requiring Frontier to pay additional taxes and interest for tax years 1995 and 1996 was timely?

FACTUAL AND PROCEDURAL BACKGROUND

¶4 The parties…