Steer, Inc. v. Department of Revenue

The Department of Revenue (DOR) appeals an order of the First Judicial District Court, Lewis and Clark County, which granted tax-exempt status to cattle owned by Steer, Inc. (Steer), on the basis that the cattle were property owned by an “institution of purely public charity” under §§ 15-6-201(1) (e), and -201(2) (a), MCA. This holding *472reversed a prior decision of the State Tax Appeal Board (STAB). We reverse the District Court’s order.

DOR raises the following issues:

1. Did the District Court err in finding STAB’s Findings of Fact IX and XI clearly erroneous?

2. Did the District Court err by…