Public Utility District No. 1 v. Department of Revenue

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter is before the court on cross motions for partial summary judgment filed by Plaintiffs (taxpayers) and Defendant (the department). One prior set of cross motions for partial summary judgment and one motion by the department for partial summary judgment have been the subject of orders of the court.

II. FACTS

In 2001, the department purported to assess and subject to property tax certain contractual rights owned by taxpayers that related to use of electric transmission facilities in the Northwest, or taxpayers’ interest, if any, in that…