Utah Ass'n of Counties v. Tax Commission Ex Rel. American Telephone & Telegraph Co.

HOWE, Justice:

The Utah Association of Counties (“UAC”) and twenty Utah counties seek review of a decision of the Utah State Tax Commission (“Commission”) assessing the fair market value of the operating property of American Telephone and Telegraph Company-Interstate Division and AT & T Communications of the Mountain States, Inc. (collectively “AT & T-C”), at $15,038,371,189 for 1990. Of that amount, $149,030,258 was allocable to Utah.

BACKGROUND

AT & T-C is a long distance telecommunications provider which is regulated by the Federal Communications Commission (“FCC”). It is considered a…