Sec. 8-3.5. Date of finality of Tax Commission decision

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Tax Law, § 1090(e)
(a) A decision of the Tax Commission shall become final upon:
(1) the expiration of the four-month period prescribed in section 8-3.1 of this Subpart, if no application for review has been made within the four-month period;
(2) the expiration of the time for all further judicial review, if an application for review has been duly made; or
(3) the rendering by the Tax Commission of a decision in accordance with the mandate of the court on review.
(b) Notwithstanding the provisions of subdivision (a) of this section, for the purpose of making an application for review, the decision of the Tax Commission shall be deemed final on the date the notice of decision is sent by certified or registered mail to the taxpayer.

                    
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