with whom CLIFFORD, J., joins, dissenting.
[¶ 24] I must respectfully dissent.
[¶ 25] The Court concludes that Thompson, who swore under oath that he was a resident of Maine in 1996, and who *895received notice of the assessment of income taxes from 1996 through 1999, can ignore the State’s actions and maintain the right to challenge those assessments at any time. I cannot square the Court’s conclusion with any legal principle.
ill 26] According to the Court, an assessor’s determination of tax liability can never be a “valid” judgment for res judica-ta purposes because the alleged taxpayer may contest the assessment based on lack of residency whenever the taxpayer wishes. On the record before us, such reasoning is not persuasive. To allow Thompson to wait until the State seeks to collect the assessed taxes and then challenge the factual basis of the assessments turns the concept of due process on its head.
[¶ 27] The Court cites to our decision in Sold, Inc. v. Town of Gorham, 2005 ME 24, 868 A.2d 172, as support for the proposition that an individual may challenge an income tax assessment based on residency at any time. In that case, the plaintiffs sought to challenge an ordinance requiring the collection of impact fees as a condition of a subdivision approval by a local planning board. Id. ¶ 1, 868 A.2d at 174. The plaintiffs brought a declaratory judgment action after the statutory time period for administrative appeal had expired. Id. ¶ 10, 868 A.2d at 176. We held that:
municipal or state actions may be collaterally attacked as outside the jurisdiction or authority of an agency, when it is claimed that the ordinance or statute under which the administrative agency purported to act was unconstitutional on its face, thus rendering the administrative action beyond the lawful authority of the challenged agency.
Id. ¶ 12, 868 A.2d at 176 (emphasis added).
[¶ 28] We ultimately concluded in Sold, Inc. that the plaintiffs could not collaterally attack the actions of the local planning board, noting that the essence of the challenge was based not on the authority of the planning board to attach conditions generally, but rather on the unconstitutionality of the specific condition imposed. Id. ¶ 13, 868 A.2d at 176-77. We held that review of such administrative actions must be brought pursuant to, and within the time allowed by M.R. Civ. P. 80B. Id. Otherwise, “there would be, in effect, no time limit to appeal any action of a municipal government — or the state government for that matter — that is alleged to be inconsistent with a statutory or constitutional requirement.” Id. ¶ 11, 868 A.2d at 176.
[¶ 29] More recently, we relied on Sold, Inc. in rejecting a due process challenge to a town ordinance designating the plaintiffs land as a strict resource protection tract. Bog Lake Co. v. Town of Northfield, 2008 ME 37, 942 A.2d 700. There, the plaintiff claimed that it was denied an opportunity to argue at a town meeting that the Town had improperly classified its land pursuant to the ordinance. Id. ¶ 14, 942 A.2d at 705. Citing to Sold, Inc., we again addressed the distinction between a facial attack on the constitutionality of an ordinance itself, which could be raised at any time, and “an attack on the procedural activity surrounding it.” Id. ¶ 13, 942 A.2d at 704-05. We ultimately concluded that the plaintiff could have argued that its land was improperly designated when it was originally classified, that the six-year statute of limitations had since passed, and that “[the plaintiffs] claim of procedural irregularities at the town meeting, even those of constitutional import, cannot resurrect [that claim] now.” Id. ¶ 14, 942 A.2d at 705.
[¶ 30] The reasoning set forth in Sold, Inc. and Bog Lake applies equally to the case before us. Thompson does not challenge the authority of the Assessor generally, nor does he present a facial challenge *896to the constitutionality of the relevant statute. At best, Thompson’s argument can be characterized as a challenge to the Assessor’s authority as applied to him, based upon his allegation that he was not a resident of Maine during the years in question. In essence, Thompson seeks a second opportunity to contest the Assessor’s determination of residency. Thompson received notice of his right to request reconsideration, and could have challenged his residency status at the time the assessments were made. Because he chose not to avail himself of the statutory process provided to him, he should not now be permitted to raise the issue of residency as a defense to enforcement.
[¶ 31] Other jurisdictions have rejected attempts by taxpayers to collaterally attack tax assessments on grounds similar to those presented by Thompson. See City of Hartford v. Faith Center, Inc., 196 Conn. 487, 493 A.2d 883 (1985) (concluding that claims of unconstitutional tax assessments are not properly raised for the first time in defense of a collection action); Krug v. City of Philadelphia, 152 Pa. Cmwlth. 475, 620 A.2d 46 (1993) (holding that failure to appeal tax assessment to the Tax Review Board results in a waiver of defenses, including lack of residency, in a subsequent enforcement action); City of Philadelphia v. Kenny, 28 Pa.Cmwlth. 531, 369 A.2d 1343 (1977) (holding that a failure to exhaust administrative review of tax assessments precludes a constitutional attack on the tax as applied). I see no reason to depart from the reasoning set forth by these courts and allow Thompson to await an enforcement action by the State before raising his lack of residency defense.
[¶ 32] Although the Court concedes that personal jurisdiction is not an issue in Thompson’s appeal, it equates its holding to previous instances in which we have held that the failure to assert the defense of lack of personal jurisdiction does not result in a waiver of that defense. However, each of the holdings relied upon by the Court have been accompanied by substantial due process concerns. See Architectural Woodcraft Co. v. Read, 464 A.2d 210, 212 (Me.1983) (“Where ... a defendant has not appeared in an action and where due process issues are generated by the exercise of personal jurisdiction over him, the defense of lack of personal jurisdiction is not waived.”); Lewien v. Cohen, 432 A.2d 800, 805 (Me.1981) (“An independent action, though rare, may be particularly appropriate where a judgment is allegedly void because it was procured by fraud and in violation of due process requirements so that an actual appearance and litigation on the merits by the affected parties were precluded.”); cf. 5C Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure, § 1391 at 522 (3d ed. 2004) (“[I]f there has been a failure of due process, that objection may permit relief from any judgment that has been entered or may be raised on collateral attack.”).
[¶ 33] Here, Thompson swore an oath that he was a resident of Maine in 1996. Thompson received notice of the assessments in that year and the ensuing three years, alerting him to his right to request a reconsideration, and he failed to take any action to challenge the assessment within the time period provided by statute. See 36 M.R.S. § 151 (2007).11 Upon these facts, Thompson received all of the process that he was due, and none of the constitutional concerns that this Court has previ*897ously expressed in conjunction with lack of personal jurisdiction are present. I am not persuaded that the record before us supports the exception carved out by the Court.
[¶34] Thompson has not presented a facial challenge to the statute nor has he demonstrated a failure of due process. Although a collateral attack on an assessor’s final determination of residency may be permissible in circumstances involving gross departures from due process requirements, I would hold that Thompson has conceded his status as a Maine resident and waived his right to challenge the Assessor’s determination on that ground by failing to request a reconsideration after earlier asserting his residence and after receiving notice of the assessments against him. Such reasoning comports with the well-established preference for the finality of administrative decisions based on “principles of judicial economy, the stability of final administrative rulings, and fairness to litigants.” Maine Cent. R.R. Co. v. Town of Dexter, 588 A.2d 289, 292 (Me.1991). Accordingly, I would affirm the judgment of the Superior Court.
. The version of section 151 in effect at the time that the Assessor sent notices to Thompson is not identical to the current version of the statute. See supra note 5 of the majority opinion.