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  5. 165 N.W.2d 250 (1969)
 

INDEPENDENT SCH. DIST. NO. 99 v. COMMISSIONER OF TAX.

No. 40628.

165 N.W.2d 250 (1969)

INDEPENDENT SCHOOL DISTRICT NO. 99, CARLTON COUNTY, et al., Appellants, v. COMMISSIONER OF TAXATION of Minnesota, Respondent, Minnesota Power and Light Company, Intervenor, Respondent.

Supreme Court of Minnesota.

February 21, 1969.

Attorney(s) appearing for the Case

Peterson & Popovich and James E. Knutson, St. Paul, Yetka & Newby, Donald Diesen, Cloquet, for appellants.

Douglas M. Head, Atty. Gen., St. Paul, Richard H. Kyle, Solicitor Gen., Don Paterick, Spec. Asst. Atty. Gen., Tax Dept., St. Paul, for Commissioner of Taxation of Minn.

Sullivan, McMillan, Hanft & Hastings, and Donald D. Harries, Duluth, for Minn. P. & L. Co.

OPINION

PETERSON, Justice.

Petitioners, Independent School District No. 99 and Thomson Township, both of Carlton County, seek to contest a 1964 order of the commissioner of taxation reducing the assessed valuation of certain property of intervenor, Minnesota Power and Light Company, situated in that county.

The commissioner of taxation has dual functions in assessment matters, the same person sitting as commissioner of

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