OPINION
BENCH, Judge:
Petitioners, Chevron U.S.A., Inc, and Amoco Oil Company, seek review of separate, but congruent, rulings by the Utah State Tax Commission. In both cases, the Commission held that petitioners' refineries would be centrally assessed for purposes of their 1989 property taxes. The cases have been consolidated for purposes of our review. We reverse.
BACKGROUND
The petitioners were notified by the Property Tax Division of...
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