Castellano v. Kosydar

This appeal presents the question of whether the period of time for filing a petition for reassessment, pursuant to R. C. 5739.13, begins to run when service of the notice of assessment is effectuated, or from the date the taxpayer receives actual notice of such assessment.

R. C. 5739.13 provides, in pertinent part:

“In each case the commissioner shall give to the person assessed written notice of such assessment. Such notice may be served upon the person assessed personally or by registered or certified mail. * * *

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“Unless the vendor or consumer, to whom said notice of assessment is…