Opinion by Judge CRISWELL.
The San Miguel County Board of Equalization (BOE) was the respondent in proceedings before the Board of Assessment Appeals (BAA) in which the BAA determined that the BOE had improperly classified for ad valorem tax purposes two parcels of realty (Lots 161 and 162) owned by petitioners, Ronald L. Von Hagen and Theresa V.H. Bucher, as vacant land, rather than as agricultural land, for the 1995 tax year. BOE appeals from that determination...
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