OPINION
GORDON, Chief Justice.
Devenir Associates (Devenir) seeks review of the court of appeals' order granting City of Phoenix's (City) motion to dismiss. The issue is whether the court of appeals erred in determining that the tax court's opinion of June 22, 1990, constituted an appealable final judgment. We have jurisdiction pursuant to Ariz. Const. art. 6, § 5(3), and A.R.S. § 12-120.24.
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