These three cases all involve a single identical issue, but the appellant has failed to show error, and we therefore affirm. The facts are not in dispute. In each of the three cases, the taxpayer raised an appeal with the Fulton County Board of Tax Assessors to its 2010 tax valuation assessment for a parcel of real property in Fulton County. In each case and on the same day, the taxpayer submitted a notice of appeal to the board and elected to use the arbitration provisions of OCGA § 48-5-311 f. Then, on July 26, 2010 and as required by that Code section, the taxpayer submitted in each case a copy of a certified written appraisal stating the estimated value of the subject property. That action triggered the beginning of the first of two 45-day periods; in the first 45-day period ending on September 9, 2010 the board of assessors was required to either formally accept or reject the taxpayer’s appraisal: Within 45 days of receiving the taxpayer’s certified appraisal, the board of assessors shall either accept the taxpayer’s appraisal, in which case that value shall become final or the county board of tax assessors shall reject the taxpayer’s appraisal, in which case the county board of tax assessors shall certify within 45 days the appeal to the clerk of the superior court of the county in which the property is located along with any other papers specified by the person seeking arbitration under this subsection, including, but not limited to, the staff information from the file used by the county board of tax assessors. OCGA § 48-5-311 f 3 A. The fact that the statute provides for two, 45-day periods has recently been established by this Court. Fulton County Bd. of Tax Assessors v. Greenfield Inv. Group, LLC , Case No. A11A1671, decided Nov. 17, 2011. As explained therein, the above quoted language establishes these two periods:
1 the period following a board’s receipt of the taxpayer’s appraisal, within which the board must formally decide to accept or reject the appraised value ; and 2 the period following a board’s decision to reject the appraised value, if it so decides, within which the board must certify the taxpayer’s appeal to the superior court so that the arbitration process can begin. Emphasis supplied. Id. The same subsection of the statute goes on to provide that should the board of assessors fail to either accept or reject the taxpayer’s appraisal within the first 45-day period, “then the certified appraisal shall become the final value.” Id.
