CIG Exploration, Inc. v. Utah State Tax Commission

ZIMMERMAN, Chief Justice:

CIG Exploration, Inc. (“Exploration”), appeals from the district court’s grant of summary judgment, dismissing Exploration’s claim for a refund of allegedly overpaid ad valorem taxes for the years 1981 through 1986. Before the district court, Exploration argued that it was entitled to a refund of taxes paid on the basis of valuations of its natural gas wells in Uintah County which, though correct as of January 1st of each relevant year, would have been lower under a subsequent state of affairs. The district court concluded that (i) Exploration’s claim was barred by…