City & County Denver v. United Air Lines, Inc.

I, INTRODUCTION

In this appeal, we address the district court's jurisdiction to hear a taxpayer's challenge to certain use and sales tax assessments levied by Denver's Manager of Revenue. Because we conclude that the district court did not have jurisdiction, we do not reach the other issues raise by the parties.

Petitioners, the City and County of Denver and its Manager of Revenue (collectively, Denver) assessed respondent, United Air Lines, Inc., certain sales and use taxes under the Denver Revised Municipal Code (D.R.M.C. or Code). United brought suit in the district court, City and County of…