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  5. 895 P.2d 819 (1995)
 

UAC v. TAX COM'N OF UTAH

Nos. 930451, 930531.

895 P.2d 819 (1995)

UTAH ASSOCIATION OF COUNTIES, a Utah nonprofit corporation, and Beaver, Box Elder, Cache, Carbon, Davis, Emery, Grand, Iron, Juab, Millard, Morgan, Rich, San Juan, Sanpete, Salt Lake, Summit, Tooele, Utah, Washington, and Weber Counties, political subdivisions of the State of Utah, Petitioners, v. TAX COMMISSION OF the STATE OF UTAH ex rel. AMERICAN TELEPHONE & TELEGRAPH CO., Interstate Division, and AT & T Communications of the Mountain States, Inc., Respondents.

Supreme Court of Utah.

Rehearing Denied April 17, 1995.

Attorney(s) appearing for the Case

Bill Thomas Peters, Salt Lake City, for petitioners.

Jan Graham, Atty. Gen., Brian L. Tarbet, Kelly W. Wright, Asst. Attys. Gen., Salt Lake City, for Tax Com'n.

Robert A. Peterson, Salt Lake City, and Anna P. Winsett, Basking Ridge, NJ, and Paul J. Mooney, Fennemore Craig, Phoenix, AZ, for AT & T.

HOWE, Justice:

The Utah Association of Counties ("UAC") and twenty Utah counties seek review of a decision of the Utah State Tax Commission ("Commission") assessing the fair market value of the operating property of American Telephone and Telegraph Company — Interstate Division and AT & T Communications of the Mountain States, Inc. (collectively "AT & T-C"), at $15,038,371,189 for 1990. Of that amount, $149,030,258 was allocable to Utah.

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