U.S. West, Inc. v. Department of Revenue

¶ 1 Following an unfavorable ruling from the State Tax Appeal Board (“STAB”), U.S. West, Inc., filed a petition for judicial review with the District Court. The District Court issued a memorandum and order upholding STAB’s ruling; U.S. West now appeals this order.

¶2 We restate the issues as follows:

¶3 1. Did the District Court err in finding that, pursuant to § 15-31-510(2), MCA (1997), U.S. West was liable for the additional interest assessed by the Department of Revenue for the tax year 1999?

¶4 2. Did the District Court err in finding that, pursuant to § 15-31-531(2), MCA (1997), U.S. West…