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Taxpayer Denied Relief After Missing Deadline Despite Timely Mailing

October 14, 2024 | Board of Equalization, Deparments in Office of the Governor, Organizations, Executive, Tennessee


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Taxpayer Denied Relief After Missing Deadline Despite Timely Mailing
In a recent government meeting, the administrative judge upheld the denial of tax relief for Mr. Naini, who failed to meet the April 5, 2023, deadline for submitting his application credit voucher (ACV). Despite Mr. Naini's assertion that he mailed his application on December 24, 2022, the judge found that the ACV was not received by the deadline, and none of the reasonable cause exceptions under Tennessee law applied to his case.

During the meeting, Mr. Naini expressed his frustration, stating that he had never missed a tax deadline before and emphasized that he was not notified of any deficiencies in his application prior to the deadline. He argued that he would have rectified the situation had he been informed, claiming that the failure to receive his application was due to postal issues.

The Shelby County assessor's office, represented by attorney Janica White, did not take a position on the matter. However, board members discussed the implications of the case, particularly regarding the burden on taxpayers to ensure timely filing. Some members expressed sympathy for Mr. Naini's situation, noting that he had demonstrated efforts to comply with the requirements.

A significant point of contention arose regarding the applicability of Tennessee statute 671803D, which addresses mailings and could potentially provide relief for taxpayers whose documents are mailed but not received. Board members debated whether this statute should be considered in Mr. Naini's case, with some suggesting that it warranted further exploration.

Ultimately, the board voted to accept Mr. Naini's position, deeming his document filed timely, despite concerns about setting a precedent for future cases. The decision reflects a recognition of the unique circumstances surrounding Mr. Naini's situation, while also highlighting the complexities of tax relief applications and the importance of timely communication between taxpayers and government offices.

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