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IN RE TAX APPEAL OF WESTERN RESOURCES, INC.

No. 74,324.

22 Kan. App.2d 593 (1996)

919 P.2d 1048

In the Matter of the Appeal of WESTERN RESOURCES, INC., From a Decision of the Director of Property Valuation.

Court of Appeals of Kansas.

Opinion filed July 12, 1996.

Attorney(s) appearing for the Case

Galen E. Biery, of Western Resources, Inc., of Topeka, and S. Lucky DeFries and Jeffrey A. Wietharn, of Coffman, DeFries & Nothem, of Topeka, for the appellant.

William E. Waters, of Division of Property Valuation, of Kansas Department of Revenue, for the appellee.

Before KNUDSON, P.J., LEWIS, J., and JACK L. BURR, District Judge, assigned.

LEWIS, J.:

In 1991, Western Resources, Inc., (WRI) began to upgrade and change its computer system. In the process, it obtained a license for application software. The process cost WRI approximately $15 million. WRI contends that its application software is intangible personal property and not taxable. It believes that the Property Valuation Division (PVD) of the Kansas Department of Revenue included the value of its...

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