OPINION
WOOD, Chief Judge.
The appeal is concerned with the evaluation for ad valorem tax purposes of mine run coal produced at the York Canyon mine of Kaiser (Kaiser Steel Corporation) in Colfax County. The three issues concern: (1) the assessed valuation; (2) the refusal to allow certain claimed deductions; and (3) the method of averaging used in determining the valuation.
The property appraisal department is the successor to the State Tax Commission...
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