OPINION
TOCI, Judge.
¶ 1 The Arizona Department of Revenue and Yavapai County (collectively "ADOR") appeals from the tax court's award of $106,240.62 in expert witness fees to Cyprus Bagdad Copper Corporation ("Cyprus"). Restated, ADOR's issues are as follows: (1) on remand from our reversal of the tax court's ruling limiting the amount of expert witness fees, is Cyprus barred by the mandate or by
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