O'NEILL v. Department of Revenue

¶1 The Department of Revenue (DOR or Department) appraised three properties owned by Daniel and Sheila O’Neill and assessed a value to each property. The O’Neills claimed the properties had been overvalued and challenged the values through appropriate administrative procedures and then to the Montana Second Judicial District Court. The District Court agreed with the O’Neills and assigned significantly lower values to the subject properties. The DOR appeals the District Court’s ruling. We reverse.

¶2 The issue before this Court is whether the District Court erred in overturning the State Tax…