Carroll Brothers, LLC, Ben's Back Alley Kitchen, LLC and Benjamin Carroll v. Christopher Graham

Summary

The court affirmed summary judgment for the Mississippi Department of Revenue, holding that the Department presented sufficient evidence that it mailed the taxpayers’ assessments and that the taxpayers’ denials of receipt did not create a triable issue. The court also held that the statutory notice provisions requiring notice by regular first-class mail satisfy procedural due process because they are reasonably calculated to inform taxpayers and provide an opportunity to challenge assessments.