Court of Appeals for the Ninth Circuit April 28, 1994, No. 92-36774 (Burlington Northern Railroad v. Department of Revenue)

Opinion by Judge Thompson.

DAVID R. THOMPSON, Circuit Judge:

The State of Washington valued Burlington Northern Railroad Company’s transportation property within the state, for ad valo-rem tax purposes, at $412.4 million for tax year 1988 and $423.5 million for tax year 1989.