City of Valdez, Appellant v. State of Alaska, North Slope Borough, and Fairbanks North Star Borough, Appellees

Summary

The Alaska Supreme Court reversed the superior court, holding that the Department of Revenue's regulation assigning taxability appeals to Revenue and valuation appeals to the State Assessment Review Board (SARB) is inconsistent with Alaska Statute 48.56, which grants SARB exclusive jurisdiction over all appeals from assessments of oil and gas property. The Court applied substitution of judgment review and interpreted "assessment" to include taxability determinations, finding the regulation invalid and remanding for entry of judgment in favor of the City of Valdez.