On Motion for Rehearing.
Appellant argues on motion for rehearing that the decision in Ledbetter Trucks, Inc. v. Floyd County Bd. of Tax Assessors, 240 Ga. 791 (242 SE2d 596), should be limited to situations in which the Board of Tax Assessors has objections to the sufficiency of notices of appeal from its decisions and should not be extended to notices of appeal from decisions of the Board of Equalization. We feel that appellant is advocating a distinction without a difference and has ignored the following statement contained in Ledbetter Trucks, Inc., supra, p. 792: “If the Board of Tax Assessors felt the notice of appeal was inadequate, it should have refused to certify the appeal until the notice was amended.” Appellant admits that, after a decision by the Board of Equalization, the Board of Tax Assessors must certify the appeal to the superior court. The certification in these cases provided that “said appellant has petitioned this appeal within his timely period...” If the notices in these cases were considered inadequate by the board, which is a party to both cases, it “should have refused to certify the appeal until the notice[s] [were] amended.” Appellant, having certified that the taxpayers have “petitioned [these] appeal[s] within [their] timely period,” may not now argue that the notices were inadequate.
Application of the Ledbetter Trucks holding to these cases is also compelled by the general rule that “[t]ax assessments and appeals should be decided on the merits of the case without procedural technicalities .. Id., p. 791. While Camp v. Boggs, 240 Ga. 127 (239 SE2d 530), may appear to be at odds with this principle, *377it should be noted that the latter case deals with statutorily imposed requirements relating to the scope of the issues, i.e., substance, of the taxpayer’s appeal.
Motion for rehearing denied.