Opinion by Judge HUME.
Petitioner, Shell Western E&P, Inc. (SWEPI), appeals from a final order of the Board of Assessment Appeals (BAA) denying its tax abatement petition. We affirm.
SWEPI owns and operates an interest in a carbon dioxide production unit which includes oil and gas leaseholds in both Montezuma County and Dolores County, Colorado. All of the producing wells in the unit are located in Montezuma County as are all of the production equipment...
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