The applicant sought a declaration that Property Assessment Change Notices issued for the 2012 and 2013 taxation years were invalid.
The notices added the value of a newly constructed hotel to the property assessment, resulting in significant additional municipal and education taxes.
The applicant argued the assessment corporation could only issue revised assessments where an omission was inadvertent and not where the property was deliberately excluded.
The court held that the governing statute permits reassessment where property has been omitted from the tax roll regardless of the reason for the omission.
The court found the hotel had been omitted due to negligence, error, inadvertence or mistake and upheld the validity of the revised assessments.
