Knopp Bros. v. Department of Taxation

This is the appeal of an order in an action brought for correction of an erroneous tax assessment. As pertinent here, Code § 58.1-1825 (formerly § 58-1130) provides that: “Any person assessed with any tax administered by the Department of Taxation and aggrieved by any such assessment may . . . within three years from the date such assessment is made, apply to a circuit court for relief.” The meaning ascribed to the word “assessment,” as used in the foregoing statute, is set forth in Code § 58.1-1820(2) (formerly § 58-1117.20(3) (Cum. Supp. 1983)). That statute provides, “ ‘Assessment,’ . . .…