Colorado Property Tax Administrator v. Co2 Committee, Inc.

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 imposed on the unit. The statutory scheme creates a representative system in which the unit operator is the sole taxpayer and point of contact for valuation, notice, audit, protest, abatement, and appeal matters. The court therefore reversed the court of appeals and affirmed dismissal of the action for lack of standing.