Amoco Production Co. v. Board of Assessment Appeals

I respectfully dissent. Today the court announces two cases that extend Coquina Oil Corp. v. Larimer County Board of Equalization, 770 P.2d 1196 (Colo.1989). *1209This case, and its companion decision, Aurora Plaza & Conference Center v. State Board of Assessment Appeals, 770 P.2d 1204 (Colo.1989), create a barrier to taxpayer recovery of an erroneous overpayment that ignores the plain wording of section 39-10-114, 16B C.R.S. (1982). For the reasons set forth in my dissent to Coquina Oil Corp. v. Larimer County Board of Equalization, I dissent to the majority opinion’s denial of the right of a…