The Pennsylvania Commonwealth Court, in Kerr v. Commw., dismissed exceptions filed by a taxpayer whose petition for reassessment was filed nearly two years after the Notice of Assessment. A Notice of Assessment was sent to the taxpayer on April 7, 2009, but the taxpayer did not file a petition for reassessment until March 25, 2011. The petition for reassessment was dismissed as untimely, and the taxpayer filed exceptions stating that he never received the Notice of Assessment. The Notice of Assessment was not stamped with a certified mail tracking number, so the Department of Revenue could not prove that it had been sent by certified mail. However, the requirements for a Notice of Assessment are set forth in Pa. Stat. Ann. Title 72 Section 7338(c) and Pa. Stat. Ann. Title 72 Section 7338(d), and neither section requires notice to be sent by certified mail. In addition, the taxpayer’s certified public accountant contacted the Department of Revenue regarding the assessment three weeks after the Notice of Assessment was mailed (with a copy of the letter sent to the taxpayer), to which the Department responded and informed the accountant of the taxpayer’s right to appeal. The court found that it is well-settled that time limitations under the Tax Code are to be strictly enforced and neither the Board nor the courts have the power to alter the explicit time limitations on equitable grounds (see Quest Diagnostics Venture, LLC v. Commonwealth, 119 A.3d 406 (Pa. Commw. 2015), aff’d, 148 A.3d 448 (Pa. 2016) and Phila. Gas Works v. Commonwealth, 741 A.2d 841, 846-47 (Pa. Commw. 1999), aff’d, 757 A.2d 360 (Pa. 2000)).