Fall River County v. South Dakota Department of Revenue

MILLER, Chief Justice.

[¶ 1] Fall River County and Edgemont School District appeal the trial court’s partial affirmance and partial reversal of the 1993 tax assessment of Burlington Northern Railroad (BNRR) performed by the South Dakota Department of Revenue (Department). We affirm in part, reverse in part, and remand.

FACTS

[IF 2] BNRR is an interstate railroad that operates in twenty-seven states and two Canadian provinces. It owns railroad operating property in seventeen counties in South Dakota. Part of BNRR’s operating property is located in Fall River County, wherein Edge-mont School…