State, Dept. of Revenue v. PPL MONTANA, LLC

¶1 PPL Montana, LLC (PPLM) appeals from the decision of the Eighth Judicial District Court, Cascade County, denying PPLM’s claim that the Montana Department of Revenue (DOR) deprived PPLM of constitutional equal protection when it assessed PPLM’s property taxes. DOR cross-appeals from the District Court’s determination to uphold the State Tax Appeals Board’s (STAB’s) decision to lower DOR’s appraisal of PPLM’s property.

¶2 We review the following issues on appeal:

¶3 Did DOR’s property tax assessment deprive PPLM of constitutional equal protection?

¶4 Did the District Court correctly affirm…