OPINION
PER CURIAM:
Respondent, an electric light and power utility company, brought action against appellants to recover over-assessments of property taxes by Clark County. Respondent contended that the alleged over-assessments resulted from the unauthorized intra-county apportionment, based on a wire-mile formula, of the unit valuation of its property apportioned to Clark County by the Nevada Tax Commission pursuant to NRS 361.320(2).
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