Boulder County Bd. of Com'rs v. Healthsouth

I disagree not only with the majority's statutory construction but also with its assumption of essential facts I consider to be hotly contested. Because I believe the court of appeals correctly interpreted the statutory scheme to provide for a refund of erroneously levied taxes, irrespective of responsibility for overvaluation of the property in question, and because I believe that, in any event, HealthSouth has neither conceded nor been given an opportunity to dispute the authority, or even apparent authority, of any officers fraudulently overvaluing its assets, I respectfully dissent.

With…