Comm'r of Revenue v. Enbridge Energy, LP

LILLEHAUG, Justice.

This case requires that we decide whether the tax court must follow an administrative *19rule on how utilities, including pipelines, should be valued for tax purposes. We conclude that the rule, including its valuation formula, is binding on the tax court.

FACTS

This case arises from challenges filed by Enbridge Energy, LP ("EELP") to the Commissioner of Revenue's valuation of EELP's petroleum pipeline system for property taxes payable in 2013, 2014, and 2015. The tax court consolidated these challenges for trial in the spring of 2015. Then, the tax court stayed the consolidated…