HOWE, Justice:
The Utah Association of Counties (UAC) and Box Elder, Morgan, Salt Lake, Utah, and Weber Counties (collectively "the Counties") seek review of a decision of the Utah State Tax Commission assessing the fair market value of the operating property of MCI Telecommunications (MCIT) for ad valorem tax purposes at $5,506,900,000 as of the lien date of January 1, 1990. The Commission determined that .45% of that amount, $24,781,050, was allocable to Utah.<...
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