WILKINS, Associate Chief Justice:
¶ 1 This case is a cross-petition for a writ of review of the Utah State Tax Commission's determination that it could equitably toll the statutory period on issuing escaped property taxes to allow its Property Tax Division to issue an assessment for such taxes against PacifiCorp, a utility company, after the statutory period for such issuances had expired; that the Utah State Tax Division's assessment of unpaid taxes was incorrect...
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