on a preprinted form signed by the taxpayer or his attorney. After a complaint was filed, a receipt tab was detached therefrom and mailed to the taxpayer notifying him of the date of the required public hearing thereon. Due to the large volume of appeals received by the board each year, complaints were reviewed by deputy commissioners, who were appointed as assistants to the board's two elected commissioners and authorized to approve reductions in tax assessments following a hearing at which it was the burden of the taxpayer to prove, by appraisal or other documentation, that the assessment was excessive. Individual taxpayers were allowed to appear at the hearing pro se, but it was a board requirement that corporate taxpayers be represented by a licensed attorney. Failure to a computer operator  devised and operated a scheme whereby persons employed by them as "runners" representing themselves as tax consultants solicited taxpayers wishing to obtain tax assessment reductions on their property. Lavin testified that typically the fraudulent complaint was prepared by either the runner, Erskine or himself and, as was the procedure with legitimate complaints, a hearing date was scheduled and notice thereof was mailed to the taxpayer-complainant. When the taxpayer, who was secretly pre-instructed to disregard the notice, failed to appear at the hearing, the complaint, which was previously "keyed" with the runner's initials, was placed in a "no appearance" drawer established to temporarily delay disapproval of complaints by taxpayers who were unable to appear at the scheduled hearing. After a few weeks, either he