Plantation Pipe Line appeals from an order of the Fulton Superior Court granting appellee State Department of Revenue’s motion for summary judgment. This case concerns a dispute over a February 13, 1981 Revenue Department assessment against Plantation for a $35,168 deficiency in its annual “corporate net worth” taxes for the years 1974 through 1980. See former Code Ann. §§ 92-2401 and 2403 (now codified in Code Ann. Ch. 91A-63). Plantation refused to pay, asserting that the manner of computing its tax under former Code Ann. §§ 92-2401 and 2403 is unconstitutional. It appealed the assessment to the superior court pursuant to Code Ann. § 91A-255, and now brings this appeal directly from the unfavorable ruling of that court.
The department has filed a motion to dismiss this appeal. It argues that Plantation has failed to comply with the appellate procedures set out in Code Ann. § 6-701.1. We agree.
“Appeals from decisions of the superior courts reviewing decisions of... State and local administrative agencies... shall be by application in the nature of a petition enumerating the errors to be urged on appeal and stating why the appellate court has jurisdiction.” Code Ann. § 6-701.1 (a) and (b). This court recently recognized that a Revenue Department assessment is a decision of a state administrative agency within the meaning of § 6-701.1.
Wheeler v. Strickland,
Plantation Pipe Line did not file an application for discretionary appeal from the decision of the Fulton Superior Court reviewing the *830 decision of the State Department of Revenue, but chose to appeal directly to this court pursuant to Code Ann. § 6-701 (a). Having failed to comply with the procedure for appeal required by § 6-701.1, Plantation’s appeal must be dismissed.
Appeal dismissed.