Kowalchik v. Brohl

Opinion by

Judge CASEBOLT.

In this taxation dispute involving conservation easement tax credits, defendant, Barbara Brohl, the Executive Director of the Colorado Department of Revenue (DOR), petitions under C.AR. 4.2 and section 13-4-102.1, C.R.S.2011, for interlocutory review of the trial court's orders holding that taxpayers who purchased conservation easement tax credits (transferees) and claimed those credits against their state income tax liability are not within the statutory definition of "taxpayer" under section 89-22-522(1), C.R.S.2011; have no tax liability for deficiencies, interest,…