Fulton County Board of Tax Assessors v. Fast Evictions, LLC, 314 Ga. App. 178

Three Fulton County tax-valuation appeals by FAST Evictions, LLC involved identical issue under OCGA § 48-5-311(f) about arbitration timing.
On the same day in 2010, FAST filed notices of appeal and elected arbitration under § 48-5-311(f).
FAST submitted certified written appraisals on July 26, 2010, triggering two 45-day periods for action by the board.
First 45-day period (ending Sept 9, 2010): board must accept or reject the appraisal; rejection triggers a second 45-day period to certify to superior court for arbitration.
Board notified FAST on Sept 23, 2010 that it rejected the appraisal and adopted a different value, but the record lacks the moment of its decision; on Oct 5, 2010 the board certified the matter for arbitration.
FAST moved to stay arbitration; trial court held the board failed to timely reject, making the certified appraisal the final value under OCGA § 48-5-311(f)(3)(A); court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether board timely rejected or accepted appraisal under § 48-5-311(f).	FAST argued the board failed to timely reject/accept within 45 days.	Board contends timing compliance standards were met or proper record established timely action.	Trial court correctly held failure to timely reject; final value enforced.

Fulton County Bd. of Tax Assessors v. Greenfield Inv. Group, LLC, 313 Ga.App. 195 (2011) (two 45-day periods; punitive language discussed)
Brown v. Frachiseur, 247 Ga. 463 (1981) (transcript and record handling burden on appellant)
Holmes v. Roberson-Holmes, 287 Ga. 358 (2010) (transcript requirements; record completeness on appeal)
Glass v. City of Atlanta, 293 Ga.App. 11 (2008) (shall as directory vs. mandatory depending on penalties)
Barton v. Atkinson, 228 Ga. 733 (1972) (time limits with penalties deemed mandatory where failure carries effect)