MACY, Justice.
Appellants Petra Energy, Inc. and Asher Associates, Inc. petitioned the district court for a review of the State Board of Equalization's decision concluding that Appellee Department of Revenue had a valid lien against the appellants' oil and gas interests in Niobrara County. The district court certified the case to this Court pursuant to W.R.A.P. 12.09(b).
We reverse.
ISSUE
The appellants present a single issue for our review...
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