Electric Power Research Institute, Inc. v. City & County of Denver

KIRSHBAUM, Justice.

The City and County of Denver (Denver) appeals1 the district court’s reversal of a decision of the Manager of Revenue of Denver’s Department of Revenue (the Department) that the Electric Power Research Institute, Inc. (EPRI) is not a charitable corporation exempt from payment of sales tax pursuant to section 53-26(2) of the Denver Revised Municipal Code (the Municipal Code). The district court ruled that EPRI is a charitable corporation for purposes of Denver sales tax exemption and that EPRI was denied due process of law by delay in the administrative review process. We…