Midan Ltd. Partnership v. District of Columbia

This appeal from the grant of a motion to dismiss on Super.Ct.Civ.R. 12(b)(6) grounds1 contests an apparent policy or practice by the District government during the tax year 1994 to give written notice regarding the potentially premature filing of tax assessment challenges to some filers but not others. Appellant makes strictly a constitutional argument, contending that the disparate notification of some taxpayers but not others of the fact that their assessment challenges might be premature for failure to pre-pay the taxes due, D.C.Code § 47-825.1(j) (1996 Supp.), violated principles of…