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[was] the authority for the city’s supplemental assessment for underassessed property under RSA 76:14.” Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 141-42 (1998).

“Because the power to tax arises solely by statute, the right to tax must be found within the letter of the law and is not to be extended by implication.” Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 143 (1998) (quotation and citations omitted).

It is well settled that the authority to tax “must be found within the letter of the law and is not to be extended by implication.” Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 143 (1998) (quotation omitted).

The trial court also ruled that RSA 76:14 and Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140 (1998), do not apply to this case.

RSA 76:14 (2012); 16 P. LOUGHLIN, New Hampshire Practice: Municipal Taxation and Road Law § 15.07, at 15-7 (2008) (“[T]he action to correct an assessment or add an excluded piece of property must occur before the expiration of the tax year for which the tax has been assessed.”); Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 142-44 (1998) (city lacked authority to assess supplemental taxes for under-assessed property based on an error in appraising the property).

RSA 75:1 (2012) (all taxable property except as identified in statute must be assessed “at its market value”); Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 143 (1998) (power to tax arises solely by statute); Mack v. Jones, 21 N.H. 393, 395 (1850) (municipalities may not “change or modify the public law regulating taxation”).

For example, in Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140 (1998), we explained that “[a] party is not required to exhaust administrative remedies where the issue on appeal is a question of law rather than a question of the exercise of administrative discretion.” Pheasant Lane Realty Trust, 143 N.H. at 141-42 (quotation omitted); see *374 also Bedford Residents Group v. Town

For example, in Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 720 A.2d 73 (1998), we explained that "[a] party is not required to exhaust administrative remedies where the issue on appeal is a question of law rather than a question of the exercise of administrative discretion."

RSA 21:2 (2000); see Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 142 (1998).

RSA 21:1,:2 (2000); see Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 142 (1998).

Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 143 (1998).

It is only in limited situations, as “where the issue on appeal is a question of law rather than a question of the exercise of administrative discretion,” Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 141-42 (1998), that a party is not required to exhaust administrative remedies.

“Because the power to tax arises solely by statute, the right to tax must be found within the letter of the law and is not to be extended by implication.” Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 143 (1998) (quotation and citations omitted).

For example, in Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 141 (1998), the City of Nashua sought to issue a supplemental tax bill on the subject property.

Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 141-42 (1998).

Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 142 (1998); Riva v. Commonwealth of Massachusetts, 61 F.3d 1003, 1007 (1st Cir. 1995) (federal statutory construction).

Pheasant Lane Realty Trust v. City of Nashua, 143 N.H. 140, 142, 720 A.2d 73, 75 (1998) (interpreting statute); Tausanovitch v. Town of Lyme, 143 N.H. 144, 147, 722 A.2d 914, 916 (1998) (interpreting zoning ordinance).