The appellants appealed a decision of the Assessment Review Board regarding the property tax classification of lands used for gravel pit operations.
The Board had classified more of the licensed land as 'industrial' rather than 'residential', interpreting the relevant regulation to include lands used for activities integral to extraction, such as processing, stockpiling, and movement of machinery.
The Divisional Court dismissed the appeal, finding that the Board correctly interpreted the legislation in a manner consistent with the operational realities of mining and properly applied the statutory classification day based on the land's function.
