Tax Assessment • Proof of Tax Owed • Overassessment to Compel Taxpayer’s Response • Preclusion of Challenge to Assessment
City of Philadelphia v. Lerner, PICS Case No. 16-1432 (Pa. Nov. 22, 2016) Wecht, J.; Donohue, J. (dissenting) (18 pages).
A taxpayer could not judicially contest a tax assessment, even if that assessment had no basis in evidence, if the taxpayer failed to exhaust his or her administrative remedies. Order of the commonwealth court affirmed.