The applicants brought a motion for a declaration that there were palpable errors in the assessment roll regarding the lot size of their property for the taxation years 2003 to 2013, and sought an extension of time to bring late appeals under s. 40.1 of the Assessment Act.
MPAC had incorrectly recorded the lot size as 7,405.2 sq. ft. larger than its actual size due to a 1963 calculation error.
The Assessment Review Board dismissed the motion, finding that the error was not 'palpable' because it was not plain and obvious, having gone unnoticed by the owners and MPAC for decades.
Consequently, the statutory precondition for exercising discretion to allow late appeals was not met.