Robert Jepson, Jr. and Alice Jepson filed this lawsuit seeking a writ of mandamus and, in the alternative, declaratory relief. They complained that when their property was reassessed, the Chatham County Board of Assessors failed to comply with OCGA § 48-5-306 e by failing to provide “a simple, nontechnical description of the basis for the new assessment.” The trial court denied the Jepsons’ request for a mandamus, but granted the Jepsons’ motion for summary judgment on the issue of declaratory relief. The Chatham County Board of Assessors appeals, arguing 1 the Jepsons’ complaint should have been dismissed because they failed to exhaust their administrative remedies, and 2 the trial court erred in finding that the Board of Assessors did not provide a simple, nontechnical description of the basis for the new assessment. Because the trial court should not have exercised its equitable jurisdiction when the Jepsons failed to exhaust their administrative remedies, we reverse the trial court’s judgment. 1. The Chatham County Board of Assessors contends that the Jepsons’ complaint should have been dismissed due to their failure to exhaust available administrative remedies.1 We agree.
The issues of reassessment, including the validity of a reassessment, shall be raised within the statutory scheme for tax appeals by an appeal to the county board of equalization or arbitrators.2 The superior court’s jurisdiction to decide issues raised by tax appeals is limited to those cases which come through OCGA § 48-5-311 g.3 While the statute addressing appeals to the county board of equalization does not specifically address notice deformities, both this Court and the Georgia Supreme Court have consistently held that the board of equalization is the appropriate forum for deciding not only questions of uniformity, valuation, and taxability, but also a taxpayer’s questions addressing constitutional and procedural issues.4 These cases establish that as a matter of public policy and judicial economy, tax questions should be resolved first at the local level through the appeal procedures created specifically for that purpose. Moreover, it is well-established that an appeal before the board of equalization provides an adequate remedy at law for the determination of county taxpayers’ questions, making unnecessary the exercise of the equitable powers of the superior court.5
