JUSTICE EID delivered the Opinion of the Court.
¶ 1 Public Service Company of Colorado ("the taxpayer"), a producer of electricity, brought a tax refund claim against the Department of Revenue of the State of Colorado ("the Department") and its executive director, Barbara Brohl, in her official capacity. The taxpayer argued that it was entitled to a refund because it had paid taxes when it was actually eligible for an exemption under section 39-26-709(1)(a)(II...
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