Justice PARRISH, opinion of the Court:
INTRODUCTION
¶ 1 The Utah State Tax Commission (the "Commission") assessed T-Mobile USA, Inc.'s ("T-Mobile") taxable Utah property for the 2003 tax year. T-Mobile sought a de novo review of the Commission's assessment in the district court, sitting as a tax court, pursuant to Utah Code sections 59-1-601 and 602. Several Utah counties
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