"It is the opinion of this Board that the taxpayer did not satisfactorily challenge the DOR's constitutional authority to appraise, assess, or equalize property values. The DOR clearly has that authority and is affirmed by the Montana Supreme Court in DOR of Revenue v. Countryside Village, (1983) 205 Mont. 51 [ 667 P.2d 936] Hanley v. DOR of Revenue, 207 Mont. 302, [673 P.2d 1251] (1983). However, along with that authority goes the duty, and the requirement, to equalize property values throughout an area, county to county, and statewide.
Clearly, this Court not only has the jurisdiction, but it has a duty, to determine the proper debt due Flathead County since none of the taxes levied by such taxing authority have been finally adjudicated under Montana law. See Dept. of Revenue v. Countryside Village, 205 Mont. 51, 667 P.2d 936, 943 (1983).In re Brummer, 15 Mont.B.R. 364, 372-373 (1996).
Clearly, this Court not only has the jurisdiction, but it has a duty, to determine the proper debt due Flathead County since none of the taxes levied by such taxing authority have been finally adjudicated under Montana law. See Dept. of Revenue v. Country Side Village, 667 P.2d 936, 943 (Mont. 1983). As noted above, Flathead County has filed its Proof of Claim as to the amount of tax due.
¶14 The statute's plain language and context thus make clear that the administrative pathway for property assessment, reassessment, and assessment appeals generally is a person's exclusive remedy for alleged excessive or erroneous assessments. See Keller v. Dep't of Revenue , 182 Mont. 478, 484, 597 P.2d 736, 739-40 (1979) (citing Larson v. State , 166 Mont. 449, 456-57, 534 P.2d 854, 858 (1975) ); Dep't of Revenue v. Countryside Vill. , 205 Mont. 51, 64-66, 667 P.2d 936, 942-43 (1983). Although we have recognized limited exceptions where fraud or the adoption of a "fundamentally wrong principle of assessment" is shown, those exceptions do not apply where, as here, "the principal thrust of the complaint is aimed at the amount of valuation and not the method of valuation."