State Dep't of Revenue v. Heidecker
Annotate this CaseRespondent purchased a 240-acre parcel of land in Gallatin County in 1980 that he rented out for grain and hay production. Respondent subdivided a thirty-acre parcel of the property in 1995. The subdivision was known as Bridger Lake Meadows (BLM). Respondent adopted covenants for BLM at the time he subdivided the property reflecting his intent that the lots be used for private residential purposes. However, Respondent sold no lots in BLM, which remained in hay and grain production. In 2009, the Department his Revenue (DOR) reclassified BLM from agricultural land to residential land. Respondent requested an informal review with DOR on the grounds that nothing had changed on the land or its usage. DOR denied the request due to the restrictions imposed by the covenants. The State Tax Appeal Board (STAB) determined that Respondent's property satisfied the statutory test for agricultural classification. The district court affirmed. The Supreme Court affirmed, holding that Respondent's continued use of the land for agricultural purposes belied any claim that the covenants "effectively prohibit" agriculture as contemplated by the amendment to Mont. Code Ann. 15-7-202(5).
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