DURHAM, Justice:
¶1 This case arises from a dispute between Union Pacific Railroad Company ("UPRR") and the Utah State Tax Commission ("Tax Commission") over the valuation of UPRR's assets for ad valorem tax purposes for the tax years 1991 through 1994. Several Utah counties (the "Counties") in which UPRR does business were also parties to the dispute before the Tax Commission.
¶2 Dissatisfied with the Tax Commission's findings of fact and conclusions...
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