Kopp v. Baird

*156SMITH, Justice.

Appellants commenced this proceeding in the first instance as a declaratory judgment action some time prior to rendition of respondent State Tax Commissioner’s formal order affirming respondent State Tax Collector’s determination of a tax deficiency. Respondent State Tax Commission had entered said order by the time appellants filed their second amended complaint.

Appellants in their second amended complaint set forth that at all the times alleged they were and now are residents of the State of Idaho; that they own lands in the State of Wyoming to which appellant Thomas R. Kopp…