City of Fort Wayne v. Southwest Allen County Fire Protection District and Tera K. Klutz, in her official capacity as Auditor of Allen County, Indiana, 82 N.E.3d 299

Southwest Allen County Fire Protection District (SWFD) is a fire protection district created in 1986. Beginning in 1987 and continuing through 2006, the City of Fort Wayne annexed fifteen areas that had been within SWFD (the Annexed Territories).
After annexation the Fort Wayne Fire Department (FWFD) began providing fire protection to those areas, but the Allen County Auditor continued to distribute property-tax revenues from those territories to SWFD rather than to the City or FWFD pension funds.
The City notified SWFD and the Auditor (August 27, 2014) that under the annexation statute (I.C. § 36-8-11-22) annexed areas cease to be part of the fire protection district once the municipality begins providing services, and thus tax revenues should be redirected to the City.
Auditor relied on an unofficial 1988 AG advisory and continued reporting assessed values for the Annexed Territories as part of the SWFD to the DLGF; the DLGF’s 1782 notices are based on Auditor-provided allocations.
The City filed a Complaint for Declaratory Judgment in Allen Superior Court seeking declaration that it is entitled to the property-tax revenues from the Annexed Territories.
Auditor and SWFD moved to dismiss under Ind. Tr. R. 12(B)(1): (1) City had not exhausted administrative remedies before the DLGF and tax court; and (2) the Indiana Tax Court has exclusive jurisdiction over matters that arise under tax law. Trial court dismissed. City appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court lacked subject-matter jurisdiction because the Indiana Tax Court has exclusive jurisdiction over disputes involving allocation of tax revenues	City: dispute is an annexation question under I.C. § 36-8-11-22 — a judicial declaration about statutory effect (which entity the territory ceased to be part of) and does not arise under tax law	Auditor/SWFD: the dispute concerns allocation/collection of property-tax revenue and thus arises under tax laws; tax court has exclusive jurisdiction	Court: Reversed dismissal. The matter is an annexation claim turning on I.C. § 36-8-11-22, not a case principally arising under tax law; trial court has jurisdiction
Whether City was required to exhaust administrative remedies (DLGF/tax court) before filing in trial court	City: may pursue declaratory relief in trial court to interpret the annexation statute; existence of administrative remedy does not bar declaratory relief under Trial Rule 57	Auditor: City should have pursued DLGF administrative process and, if necessary, appealed to tax court	Court: Exhaustion route was available but does not deprive the trial court of jurisdiction to decide the annexation declaratory claim; declaratory relief remains appropriate

State ex rel. Ind. Att’y Gen. v. Lake Superior Court, 820 N.E.2d 1240 (Ind. 2005) (discusses creation and purpose of Indiana Tax Court and its jurisdiction over tax disputes)
State ex rel. Zoeller v. Aisin USA Mfg., Inc., 946 N.E.2d 1148 (Ind. 2011) (explains that cases held to arise under tax law involve disputes over interpretation or application of tax statutes)
State v. Sproles, 672 N.E.2d 1353 (Ind. 1996) (defines when a case "arises under" the tax laws)
Wayne Twp. v. Ind. Dept. of Local Government Finance, 865 N.E.2d 625 (Ind. Ct. App. 2007) (held tax court had exclusive jurisdiction where the dispute principally involved collection/allocation of tax levies)
Bader v. Johnson, 732 N.E.2d 1212 (Ind. 2000) (explains de novo review for questions of law where trial-court facts are undisputed)