Puget Sound Energy, Inc. v. State

¶1 Montana Department of Revenue (Department) appeals the judgment of the Thirteenth Judicial District Court, Yellowstone County that concluded that the State Tax Appeal Board (STAB) could not assess Puget Sound Energy’s (Puget) market value in excess of the Department’s original assessment. We reverse.

¶2 We review the following issue on appeal:

¶3 Did the District Court correctly conclude that STAB may not assess Puget’s market value in an amount that exceeds the Department’s original assessment?

FACTUAL AND PROCEDURAL BACKGROUND

¶4 The Department issued final ad valorem assessments of Puget…