Kowalchik v. Brohl

Opinion by JUDGE WEBB

¶ 1 In this dispute involving conservation easement (CE) tax credits, we granted the petition of defendant, Barbara Brohl, the Executive Director of the Colorado Department of Revenue (DOR), for interlocutory review of the trial court's orders in favor of plaintiffs,1 holding that persons who purchased CE tax credits (transferees) from plaintiffs: are not within the statutory definition of "taxpayer" under section 39-22-522(1), C.R.S.2011; have no tax liability for deficiencies, interest, and penalties for the improper claim of a tax credit; need not be joined as…