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MONTANA DEPT. OF REVENUE v. SHEEHY

No. 93-193.

862 P.2d 1181 (1993)

THE MONTANA DEPARTMENT OF REVENUE, Petitioner and Appellant, v. John C. and Rita Ann SHEEHY Respondents and Respondents.

Supreme Court of Montana.

Decided November 18, 1993.

Attorney(s) appearing for the Case

David W. Woodgerd, Chief Legal Counsel; Lawrence G. Allen, Tax Counsel, Department of Revenue, Helena, for petitioner and appellant.

John C. Sheehy, Pro Se.

HUNT, Justice.

This is an appeal from an order of the First Judicial District Court affirming the decision of the State Tax Appeal Board (STAB). The STAB ruled that DOR's use of a stratified sales assessment ratio study to determine a value multiplier, as applied to the respondents' (Sheehys) home, caused the same disparity of treatment of taxpayers within a specified area as that determined by this Court in Department of Revenue v. Barron (1990), 245 Mont...

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