Colorado Property Tax Administrator v. CO 2

Summary

The court held that nonoperating fractional interest owners in a unitized oil and gas operation lack standing to independently challenge a retroactive property-tax assessment or increase. Under the statutory and administrative scheme, the unit operator is the sole taxpayer and representative for valuation, notice, audit, protest, abatement, and appeal purposes. The court therefore reversed the court of appeals and affirmed dismissal of the action for lack of standing.