Parisian, Inc. sued the Cobb County Board of Tax Assessors BTA primarily to seek injunctive relief from a scheduled four-year tax audit. Parisian appeals the grant of summary judgment to the BTA.1 Because we find material issues of disputed fact that preclude summary adjudication, we reverse. On summary judgment, this Court conducts a de novo review of the entire record to determine whether the trial court erring in its ruling. Rubin v. Cello Corp. , 235 Ga. App. 250 510 SE2d 541 1998. Summary judgment is appropriate when the facts and evidence and reasonable inferences therefrom are considered in a light most favorable to the nonmovant and do not demonstrate the existence of a triable issue. Id. at 251. So considered, the evidence shows that the BTA reassessed Parisian’s 2000 personal property tax return for its inventory in its Town Center Mall store in Cobb County after Glenn Heckman, an appraiser in the tax assessors’s office, noticed a reduction in the value assigned by Parisian to its inventory for that tax year. Heckman decided to “roll over the prior year’s, 1999′s, inventory value.” After adjusting the value of Parisian’s personal property inventory back to the 1999 value, the BTA notified Parisian of its reassessment.
In response, on July 7, 2000, Parisian timely filed an ad valorem tax appeal for tax year 2000 to challenge that reassessment. Over the next several months, Parisian and the BTA attempted to resolve the valuation issue. The quantity and wholesale cost of Parisian’s personal property inventory were never in dispute. At issue was whether that inventory should be valued at its wholesale cost without reduction or should be valued at its wholesale cost less a percentage of markdowns, cash allowances, and vendor discounts that Parisian claimed reflect the inventory’s true market value. To support its calculation of the inventory’s actual value, Parisian submitted documentation to the BTA. An independent tax consultant and certified public accountant, Randy Ochs, provided a detailed analysis to explain the basis for valuing the inventory at less than wholesale cost. On October 19, 2000, Ochs explained to Heckman why Parisian’s stock ledger system overstated the true value of the inventory. Ochs attached supporting documentation to his letter. Notwithstanding Parisian’s explanations about discounts, markdowns, and allowances, Melvin R. Plunkett, the division manager of personal property in the tax assessors’s office, rejected Parisian’s analysis. Plunkett testified, “it remained open as an open appeal, because we did not accept their reductions in inventory value.” After negotiations on valuing the inventory floundered, Donald M. Barnhill, Parisian’s national property tax director, contacted Plunkett directly in a final effort to settle the issue. Unable to resolve the impasse, Barnhill decided to appeal to the Board of Equalization BOE. While Parisian’s appeal to the BOE was pending, the BTA notified Parisian that it would have to undergo a four-year audit for tax years 2000, 1999, 1998, and 1997.
