Brazilia, L.L.C. v. Collector of St. Louis County

OPINION

GLENN A. NORTON, Presiding Judge.

Brazilia, L.L.C. appeals the judgment granting the Collector of St. Louis County's motion to dismiss Brazilia’s petition to recover taxes it paid under protest and entering judgment in the Collector’s favor. We agree that the petition should have been dismissed for lack of subject matter jurisdiction. But, lacking jurisdiction, the trial court should not have entered judgment for the Collector. We dismiss the appeal.

I. BACKGROUND

In its petition, Brazilia alleged that it had paid taxes under protest on real property in St. Louis County. Attached to the…