OPINION
HATHAWAY, Chief Judge.
Appellants have appealed from a judgment entered against them upon appellee's motion for summary judgment.
American Smelting & Refining Company, a New Jersey corporation, hereinafter called ASARCO or the plaintiff, filed a complaint in the Superior Court of Pima County seeking to recover from Pima County, property taxes paid under protest, as follows:
TAX YEAR ...
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