Robert Jepson, Jr. and Alice Jepson filed this lawsuit seeking a writ of mandamus and, in the alternative, declaratory relief. They complained that when their property was reassessed, the Chatham County Board of Assessors failed to comply with OCGA § 48-5-306 (e) by failing to provide “a simple, nontechnical description of the basis for the new assessment.” The trial court denied the Jepsons’ request for a mandamus, but granted the Jepsons’ motion for summary judgment on the issue of declaratory relief. The Chatham County Board of Assessors appeals, arguing (1) the Jepsons’ complaint should have been dismissed because they failed to exhaust their administrative remedies, and (2). the trial court erred in finding that the Board of Assessors did not provide á simple, nontechnical description of the basis for the new assessment. Because the trial court should not have exercised its equitable jurisdiction when the Jepsons failed to exhaust their administrative remedies, we reverse the trial court’s judgment.

1. The Chatham County Board of Assessors contends that the Jepsons’ complaint should have been dismissed due to their failure to exhaust available administrative remedies.1 We agree.

The issues of reassessment, including the validity of a reassessment, shall be raised within the statutory scheme for tax appeals by an appeal to the county board of equalization or arbitrators.2 The superior court’s jurisdiction to decide issues raised by tax appeals is limited to those cases which come through OCGA § 48-5-311 (g).3 While the statute addressing appeals to the county board of equalization does not specifically address notice deformities, both this Court and the Supreme Court of Georgia have consistently held that the board of equalization is the appropriate forum for deciding not only questions of uniformity, valuation, and taxability, but also a tax*772payer’s questions addressing constitutional and procedural issues.4 These cases establish that as a matter of public policy and judicial economy, tax questions should be resolved first at the local level through the appeal procedures created specifically for that purpose. Moreover, it is well established that an appeal before the board of equalization provides an adequate remedy at law for the determination of county taxpayers’ questions, making unnecessary the exercise of the equitable powers of the superior court.5

While the principles argued by the dissent hold a certain allure and it is true that the system of appeals set up under the statutory framework can be somewhat burdensome, the legislature and Supreme Court precedents mandate that taxpayers must timely appeal questions such as the one presented here before the board of equalization. Even if the notice sent to the Jepsons failed to provide a nontechnical description of the basis for the new assessment, this failure did not render an effective appeal to the Board of Assessors impossible. The Jepsons could have appealed to the Board of Assessors and argued that the language failed to comply with the requirements of OCGA § 48-5-306, just as they argued in the present case. At that point, the Board of Assessors could have either accepted or rejected their argument, and the Jepsons would have exhausted their administrative remedies.

Moreover, it is clear from the record that the Jepsons’ time for appeal to the Board of Assessors had expired before they filed the declaratory judgment action at issue.6 Allowing them to avoid the statutory appeal requirements by filing a declaratory judgment action after their administrative appeal time had expired opens the door for many such actions in the future, a burden on judicial resources which the legislature had relieved in enacting the administrative appeal process for cases such as this one. In addition, adopting the procedure the dissent urges would allow the Jepsons to pursue an appeal, their rights to which they had clearly waived by allowing the time for an appeal to the Board of Assessors to expire.

The Jepsons must raise their tax issues, including the issue of whether they received valid notice, before the board of equalization and exhaust their administrative remedies by the statutorily provided appeal. The trial court should have dismissed this suit for failing to state a claim.7

*7732. Based on our holding in Division 1, we need not address the Chatham County Board of Assessors’ contention that the trial court erred in holding that the change of value notice was not accompanied by a simple, nontechnical description of the basis for the new assessment. We note that nothing in this opinion is intended to indicate this Court’s views as to the merits of the Jepsons’ claim.

Judgment reversed.

dissenting.

I respectfully dissent, for three reasons. First, the notice sent to the Jepsons fell so far short of the new “nontechnical description” requirement of OCGA § 48-5-306 (e) that an effective appeal to the board of equalization (“BOE”) was impossible. Second, a declaratory judgment action is not an equitable proceeding and is appropriate in some ad valorem tax disputes. And, third, although resolving tax questions at the local level through the appeal process created specifically for that purpose obviously is a commendable goal, it is unrealistic to pretend that the overworked BOEs, staffed by volunteer laypersons, without legal training, law clerks or law books, can decide constitutional and procedural issues, including the statutory application question raised by the Jepsons. Our Court, and the Supreme Court of Georgia, should reconsider those precedents8 which now require the boards to decide issues far beyond their already heavy statutory mandate: uniformity, valuation, taxability, and homestead exemptions.9

1. OCGA § 48-5-306 (e) specifies that “[w]here . . . the value of the taxpayer’s real property subject to taxation exceeds the returned value of such property by 15 percent or more, the notice required by this subsection shall be accompanied by a simple, nontechnical description of the basis for the new assessment.” It is undisputed *774that the new valuation exceeded the returned value by more than 15 percent. The trial court found that the explanation given “use[d] terms of art and an abbreviation that is difficult to decipher, is vague and could be interpreted as redundant. . . .” In short, according to the trial court’s judgment, the description provided by the Board of Assessors did not provide a “simple, nontechnical description of the basis for the new assessment.”10 The trial court properly framed relief by requiring the Assessors to provide the Jepsons with notices that comply with the statute and staying any collection of taxes based on the increased assessment until the taxpayers had an opportunity for a hearing before the BOE.

Because the notice here failed to comply with the statute, Dillard v. Denson, 11 cited by the majority in support of its conclusion that the Jepsons’ complaint should have been dismissed because they failed to exhaust their administrative remedies, is distinguishable. The taxpayer in Dillard alleged that he never received the notice, although it was sent to him by first class mail to the address he had specified in his request for a building permit. However, the contents of the notice and the method by which it was sent precisely complied with the statute. Accordingly, we held in Dillard that the notice satisfied due process requirements. By contrast, in the case at bar, the taxpayers received a notice, but its contents failed to comply with the statute.

Nor does Chilivis v. Backus12 warrant reversal of the trial court’s judgment. Although Chilivis recited that the validity of notices should be litigated in the BOE, it went on to affirm the trial judge’s ruling on the timeliness of the notices and to allow the sending of amended, correct notices.13 This is precisely the relief which the trial judge specified in the case at bar. The Chatham Superior Court judgment does not allow the Jepsons to bypass the BOE, nor does it allow them to escape paying whatever taxes they owe. It merely requires the Assessors to provide an adequate, nontechnical notice so that the taxpayers have a fair chance to frame their appeal properly before the BOE.

The trial court’s decision accords with the new statutory requirement and with due process of law.14 “The fundamental idea of due *775process is notice and an opportunity to be heard.”15 Both the Supreme Court of Georgia and the Supreme Court of the United States have repeatedly emphasized this principle. And, as explained in Gilmore v. Curry,16 “[a] statute providing for notice, in a case like the present one, where for failure of service!,] a man may be deprived of his property, must be strictly construed.”17 In the case at bar, although the Jepsons received a notice that their assessment had been raised, the reasons given for the increase in their assessment were not written in “simple, nontechnical” language, as required by OCGA § 48-5-306 (e). Instead, the notice was worded in codes that necessitated explanation by the county’s chief appraiser. Indeed, the Jepsons’ expert witness, a real estate appraiser with 25 years of experience in dealing with ad valorem taxation assessments, testified that he had no idea what one of the reasons given, “Neighborhood CD,” meant until the chief appraiser defined it at the hearing. How can a taxpayer adequately prepare for his hearing before the BOE when he does not know why his assessment was raised? As the learned trial judge explained, “[w]ithout a ‘simple, nontechnical description of the basis for the new assessment,’ a taxpayer is placed in the unenviable position of deciding whether to file an appeal which may turn out to be groundless or frivolous in order to simply receive an explanation for the increased assessment.” This is precisely the kind of “uncertainty and insecurity” that the Declaratory Judgment Act is intended to ameliorate.18

2. OCGA § 9-4-2 (c) states that relief by declaratory judgment “shall be available, notwithstanding the fact that the complaining party has any other adequate legal or equitable remedy or remedies.”19 Despite this language, our courts have often held that declar*776atory relief is not available when a statute has given a party a means of review by an administrative agency.20 These decisions are based on the sound reasoning that, if declaratory actions were allowed in these circumstances, “then all questions pending before administrative tribunals could be decided by the courts . . . and the beneficial purposes of administrative tribunals would be frustrated.”21 Additionally, many decisions recite that the equity jurisdiction of the superior courts is inappropriate in ad valorem tax disputes.22 However, an action brought under the Declaratory Judgment Act is an action at law, even if it seeks a temporary restraining order.23 Moreover, this Court has expressly approved the use of declaratory judgment actions in ad valorem tax disputes, explaining:

An action for declaratory judgment is not a substitute for an appeal under OCGA § 48-5-311 (e), but such is appropriate in this case, not for the purpose of resolving reassessment issues that should come under OCGA § 48-5-311, but to “guide the parties and prevent uncertainty and insecurity with respect to the propriety of some future act or conduct in order not to jeopardize their interests,” regarding statutory application and construction.24

In the instant case, declaratory relief is especially appropriate because both parties require guidance regarding the application of *777OCGA § 48-5-306 (e).25 The county’s chief appraiser testified that despite repeated requests, the Department of Revenue had given the Assessors no directives on how to provide nontechnical explanations to the taxpayer. The Assessors then devised “reason codes” for assessment increases, but these obviously missed the mark. The Jepsons, in turn, complain that OCGA § 48-5-311 (e) requires a simple, nontechnical explanation, an explanation they did not receive. They are uncertain as to the reasons for the increaséd assessment and hence uncertain about their future actions in an appeal to the BOE. The defective notice might jeopardize their interests by precluding them from raising issues which an adequate notice might have revealed. The Jepsons do not seek review of reassessment issues (i.e., taxability, uniformity of assessment, value, or denial of household exemption), which the General Assembly has by statute expressly entrusted to the BOE. In sum, the Assessors and the taxpayers needed guidance, which the trial court properly dispensed when it ordered declaratory relief.26

Indeed, declaratory relief was deemed an appropriate remedy in James B. Beam Distilling Co. v. State of Ga.27 notwithstanding the availability of an administrative remedy. In that case, our Supreme Court held that declaratory relief is available to a taxpayer “prior to payment of disputed taxes . . . even if the party has other . . . legal or equitable remedies.”28 The preference for abstention from declara*778tory relief in ad valorem tax cases derives, in part, from dicta appearing in a later decision, Glynn County Bd. of Tax Assessors v. Haller.29 Presiding Justice Fletcher, now Chief Justice, pointed out that the United States Supreme Court has held that state courts should not award “either declaratory or injunctive relief against state taxes under [42 USC] section 1983 when there is an adequate legal remedy.”30 But the case at bar is not an action brought under § 1983, and the Haller decision went on to rule that injunctive relief had been improper. Declaratory relief had not been sought in Haller. In conclusion, no Supreme Court of Georgia decision expressly forbids declaratory actions in tax cases, while James Beam approves them without equivocation. I would affirm the judgment below.