MPAC brought a motion arguing that the doctrine of issue estoppel applied to the appellant's property assessment appeals for the 2009-2012 taxation years, as the property's classification had been previously litigated.
The appellant opposed, arguing a change in material facts due to a 10% increase in retail sales at the bakery operation.
The Assessment Review Board dismissed the appellant's procedural objection regarding notice and granted MPAC's motion.
The Board found that the three requirements for issue estoppel were met and that the minor change in retail business did not alter the property's industrial classification.
