State of Colorado, Colorado Department of Revenue and Executive Director of the Colorado Department of Revenue…

Summary

The court held that the four-year limitations period for invalidating a conservation-easement tax credit begins when the donor claims the credit, and that period binds transferees of the credit. Because the donor filed its return in 2007 and the Department disallowed the credit in 2011, the disallowance was timely. The court relied on the statute's plain language and therefore did not decide whether the Department's regulation independently deserved deference.