Boulder County Board of Commissioners; and Joann Groff, Colorado Property Tax Administrator, and Bo — Coats, J…

Summary

Justice Coats dissented from the majority's construction of the property-tax abatement and refund statutes. He would allow a refund for taxes erroneously levied on property not located in the county, regardless of whether the overvaluation resulted from taxpayer conduct, so long as the statutory abatement process was followed. He also maintained that the record did not establish that HealthSouth or its authorized agents intentionally caused the overvaluation or that HealthSouth had been given an opportunity to litigate that issue.