Union Pacific Railroad v. State Tax Commission of Utah

I dissent again and re-affirm what I said in the case in which this petition for rehearing and reargument was granted (426 P.2d 231). I also concur in the dissenting opinion of Mr. Justice Callister in that case. I also concur in the dissenting opinion of Mr. Orville Gunther, Commissioner of the Tax Commission, who, after analyzing the legislation involved, pointed out that if the legislature had intended to impose the tax on railroads, it specifically could have said *238so in a very few words, and not having done so, any doubt (which arose after 22 years of administrative undoubt) should be…