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Monetary limits on appeal filings regulate State tax officer litigation but do not imply acquiescence by non-filing. The Commissioner, on the Council's recommendation, may issue orders fixing monetary limits to regulate filing of appeals or applications by State tax officers; non-filing pursuant to those limits does not preclude filing in other cases involving the same or similar issues, nor may it be relied on by a party as evidence of acquiescence, and tribunals or courts must regard the circumstances of such non-filing.
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<h1>Monetary limits on appeal filings regulate State tax officer litigation but do not imply acquiescence by non-filing.</h1> The Commissioner, on the Council's recommendation, may issue orders fixing monetary limits to regulate filing of appeals or applications by State tax officers; non-filing pursuant to those limits does not preclude filing in other cases involving the same or similar issues, nor may it be relied on by a party as evidence of acquiescence, and tribunals or courts must regard the circumstances of such non-filing.