With no explanation, chose the best option from "A", "B", "C" or "D". the BAA had jurisdiction and a statutory duty to "hear" taxpayer's appeals. See §§ 39-2-125(1)(f), 89-10-114.5(1), C.R.S. 2008; 5050 S. Broadway Corp. v. Arapahoe County Bd. of Comm'rs, 815 P.2d 966, 968-69 (Colo.App.1991) In such administrative appeals, the BAA is not limited to a review of any previous action taken, but instead is authorized to conduct de novo evidentiary proceedings on the merits of the abatement and refund claims. See D.C. Burns Realty & Trust v. Jefferson County Bd. of County Comm'rs, 849 P.2d 900, 903 (Colo.App.1992). Nevertheless, even when the BAA has subject matter jurisdiction to hear such appeals, the substantive limitations on abatement and refund elaims found in other statutory provisions remain applicable. See 5050 S. Broadway Corp., 815 P.2d at 968-71 (<HOLDING>). Here, the BAA stated that it had "heard"

A: holding that baa had jurisdiction to hear the appeal but affirming baas denial of abatement and refund claims as unauthorized under statutory scheme
B: holding that failure to file brief on appeal to bia constitutes ineffective assistance but affirming the denial of habeas because petitioner could not show prejudice
C: holding in pertinent part that this court lacked jurisdiction to hear the appeal
D: holding that we lack jurisdiction to hear an appeal of the bias denial of a motion to reopen based on its sua sponte authority
A.