The appellant appealed the property assessment for the 2020 to 2022 taxation years, arguing that the current value of the property had decreased due to COVID-19 regulatory restrictions.
The respondent brought a motion to dismiss the appeals, arguing that the correct valuation day remained January 1, 2016, and that the issue of the property's value as of that date had already been resolved by a settlement agreement for the 2018 and 2019 taxation years.
The Assessment Review Board found that the correct valuation day was January 1, 2016, and applied the doctrine of issue estoppel to prevent the appellant from re-litigating the property's value.
The appeals were dismissed.