KITE, Justice.
[¶ 1] PacifiCorp, Inc. (PacifiCorp) appealed its ad valorem valuations for tax years 1997, 1998, and 1999 claiming the Department of Revenue (the Department) undervalued its tax exempt pollution control equipment resulting in an overpayment of tax. The State Board of Equalization (the Board) affirmed the Department's action. PacifiCorp filed a petition for review in the district court, and the district court certified the case to this court pursuant...
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