FIRST AMERICAN TITLE COMPANY OF NEVADA v. State

OPINION

Appellant paid, under protest, property taxes on land located in Douglas County. Subsequent to payment, appellant instituted this action attacking the assessed valuation of the property, pursuant to NRS 361.420. 1 The district court granted respondent’s motion to dismiss because appellant failed to challenge the valuation before the county and state boards of equalization, before filing suit, as required by NRS 361.410(1).

Appellant here contends that compliance with NRS 361.-410(1) is not a condition precedent to filing suit under NRS 361.420, because the latter states a separate and…