HEAVICAN, C.J.
INTRODUCTION
The Banner County assessor set the 2005 valuation on certain parcels of property owned by Darnall Ranch, Inc. (DRI). DRI protested those valuations. At a hearing, the Banner County Board of Equalization (Board) agreed with the valuations placed on the properties. DRI appealed to the Tax Equalization and Review Commission (TERC). Meanwhile, in a separate case, the Nebraska Court of Appeals voided the valuations,
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