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GUARDIAN ENERGY, LLC v. COUNTY OF WASECA

Nos. A14-1883, A14-2168.

868 N.W.2d 253 (2015)

GUARDIAN ENERGY, LLC, Relator, v. COUNTY OF WASECA, Respondent.

Supreme Court of Minnesota.

August 12, 2015.

Attorney(s) appearing for the Case

Thomas R. Wilhelmy , Jennifer A. Kitchak , Fredrikson & Byron, P.A., MN, Minnesota, for relator.

Marc J. Manderscheid , Michael M. Sawers , Briggs and Morgan, P.A., Minneapolis, MN; and Brenda Miller , Waseca County Attorney, Waseca, MN, for respondent.

Robert Small , Executive Director, Minnesota County Attorneys Association, Saint Paul , MN; and John March , Senior Hennepin County Attorney, Jane N.B. Holzer , Thomas F. Pursell , Assistant Hennepin County Attorneys, Minneapolis, MN, for amicus curiae Minnesota County Attorneys Association.

OPINION

In a proceeding before the Minnesota Tax Court, relator Guardian Energy, LLC, challenged respondent Waseca County's assessment of the value of its ethanol-production facility. In this appeal from the tax court's order for judgment, Guardian Energy argues that the tax court erred by (1) classifying 27 tanks

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