HOWE, Associate Chief Justice:
This case is before us on a writ of review to the Utah State Tax Commission. Salt Lake County seeks review of a decision of the Commission that seven contiguous parcels of vacant land totalling approximately 431.41 acres in Salt Lake County qualified for assessment under the Farmland Assessment Act of 1969 (F.A.A.), Utah Code Ann. §§ 59-5-86 to -105 (1986).
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