Riley, J.
STATEMENT OF THE CASE
Appellant-Plaintiff, the City of Fort Wayne (City), appeals the trial court’s dismissal of its Complaint for Declaratory Relief against Appellees-Defendants, the Southwest Allen County Fire Protection District (SWFD) and Tera K. Klutz,1 in her official capacity as Auditor of Allen County, Indiana (Auditor), for lack of subject matter jurisdiction pursuant to Indiana Trial Rule 12(B)(1). [Footnote omitted.]
We reverse and remand.
ISSUE
The City raises one issue for our review, which we restate as: Whether the trial court committed reversible error by dismissing the City’s claim for lack of subject matter jurisdiction pursuant to Ind. T.R. 12(B)(1).
….
The Allen Superior Court has “original and concurrent jurisdiction in all civil cases and in all criminal cases.” Ind. Code § 33-29-1-1.5. In 1986, the General Assembly created the Indiana Tax Court to channel tax disputes into a single specialized tribunal, thereby ensuring the uniform interpretation and application of the tax laws. State ex. rel. Ind. Att’y Gen. v. Lake Superior Court, 820 N.E.2d 1240, 1247 (Ind. 2005), reh’g denied, cert. denied, 546 U.S. 927 (2005). As such, the tax court has exclusive subject matter jurisdiction over “original tax appeals.” I.C. §§ 33-26-3-1; -3. Accordingly, if the tax court has jurisdiction over this case, then the trial court does not.
Though exclusive, the tax court’s jurisdiction is limited to “original tax appeals.” I.C. § 33-26-3-3. An original tax appeal is a case that arises under tax laws and it must be an initial appeal of a final determination of a state revenue agency. Id. A case arises under the tax laws if (1) “an Indiana tax statute creates the right of action,” or (2) “the case principally involves collection of a tax or defenses to that collection.” State v. Sproles, 672 N.E.2d 1353, 1357 (Ind. 1996). Our supreme court has construed the tax court’s jurisdictional mandate broadly, so as to ensure a “single authoritative voice on state tax matters.” State ex rel. Zoeller v. Aisin USA Mfg., Inc. 946 N.E.2d 1148, 1153 (Ind. 2011), reh’g denied; Garwood v. State, 77 N.E.3d 204, 215 (Ind. Ct. App. 2017). For example, any case challenging the collection of a tax or assessment arises under the tax laws, whether the challenge is premised on constitutional, statutory, or other grounds. State v. Costa, 732 N.E.2d 1224, 1224-25 (Ind. 2000). And the challenge need not be to the collection directly—challenges to earlier steps in the taxation or assessment process will also be characterized as arising under the tax laws. See, e.g., Lake Superior Court, 820 N.E.2d at 1247 (challenging reassessment of property valuations on which property-tax calculation would be based). In sum, a case principally involves a tax collection or the defenses thereto if the taxpayer contests or challenges tax liability imposed on her by the tax laws. Garwood, 77 N.E.3d at 205.
Relying upon the annexation statute, as enacted in I.C. § 36-8-11-22, the City contends in its Complaint that the “property tax revenues derived from [the Annexed Territories] should have been and should now and in the future be directed to the City, specifically to the FWFD and Fire Pension funds.”….
In response, the Auditor advocates for the application of Indiana’s tax laws— specifically I.C. §§ 33-26-3-1; -2(1), the general statute conferring limited jurisdiction on the tax court—as they view the case of one involving the distribution of tax revenues….
Based on the specific facts before us, we determine that the present case is an annexation case and requires no consideration of substantive tax law. The parties do not dispute the tax assessments and do not request a change in tax levies, nor are the parties attempting to collect a tax. No calculation to determine a specific tax assessment must be made, and no interpretation of tax laws is required. Rather, the City’s dispute merely centers on the intended recipient of taxes already assessed and collected, pursuant to I.C. § 36-8-11-22. This is not “quintessentially [a] tax matter.” Zoeller, 946 N.E.2d at 1153.
Although annexation inevitably affects the allocation of tax revenue among units of government within the annexed area, it does not automatically follow that an action for a declaratory judgment with respect to an annexation statute arises under Indiana tax law and involves a dispute as to the interpretation of a tax law. See Zoeller, 946 N.E.2d 1155 (“Every case that this [c]ourt has held arises under Indiana tax law has involved a dispute as to the interpretation or application of a tax law.”). Here, there is no tax law that needs interpreted or applied for the trial court to declare whether the City is entitled to property tax revenue derived from the Annexed Territories. A trial court is not ousted of its jurisdiction to interpret I.C. § 36-8-11-22, an annexation statute, merely because the Auditor and the DLGF have exclusive responsibility for calculating the allocation of tax revenue within the Annexed Territories. [Footnote omitted.] Accordingly, we conclude that the trial court has subject matter jurisdiction over this dispute. We reverse the trial court’s Order and remand for further proceedings.
CONCLUSION
Based on the foregoing, we conclude that the trial court has subject matter jurisdiction to decide the City’s request for declaratory judgment.
Reversed and remanded.
Najam, J. and Bradford, J. concur