The three appellants in this case are Dougherty County property owners1 “Property Owners”, who challenged the County Tax Assessors’ alleged failure to properly assess real and personal property interests held by utility companies, and to uniformly assess other real and business personal property located in the county. After the Dougherty County Board of Equalization denied their claims, the Property Owners appealed to the superior court. The superior court denied the Property Owners’ motion for summary judgment and partially granted the County Tax Assessors’ motion for summary judgment. The Property Owners filed the instant appeal, and for reasons that follow, we affirm.
1. Before turning to the merits of the Property Owners’ appeal, we must address two impediments to our review posed by their appellate brief. First, the Property Owners enumerate nine errors, but have not shown how they preserved these nine asserted errors for review. It is not our function to cull the record to insure that the Appellants properly raised the arguments below. Court of Appeals Rule 27 a 1 clearly places that burden on Appellants. Second, notwithstanding their nine enumerated errors, the Property Owners’ brief contains only two sections of argument. Court of Appeals Rule 27 c 1 requires that arguments “follow the order of the enumerations of error, and shall be numbered accordingly.”2 The rule is not a mere formality, but is intended to assist the Court in addressing the individual merits of each enumerated error. By failing to separately address each assertion and not showing how they were preserved, the Property Owners have seriously hampered our review of their appeal. These deficiencies are all the more troubling because we granted the Property Owners’ motion to exceed the 30-page limit imposed by Court of Appeals Rule 23 e. Though we will address the merits of the arguments raised, the Property Owners are wholly responsible for any claim that we have failed to sufficiently address in each of their nine enumerated errors.
