Utah Code » Title 59, Chapter 1 — General Taxation Policies; part 59-1-6 — Judicial Review
Utah Code

Utah Code § 59-1-610 (2026)

Standard of review of appellate court

✓ current as of May 2026
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When reviewing formal adjudicative proceedings commenced before the commission, the Court of Appeals or Supreme Court shall:
grant the commission deference concerning its written findings of fact, applying a substantial evidence standard on review; and
grant the commission no deference concerning its conclusions of law, applying a correction of error standard, unless there is an explicit grant of discretion contained in a statute at issue before the appellate court.
This section supercedes Section 63G-4-403 pertaining to judicial review of formal adjudicative proceedings.
Notes of Decisions
Cited in 78 cases (4 in the last 5 years), 1993–2025 · leading case: Yeargin, Inc. v. Auditing Div. of Utah State Tax Comm'n, 2001 UT 11 (Utah 2001).
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Yeargin, Inc. v. Auditing Div. of Utah State Tax Comm'n, 2001 UT 11 (Utah 2001). · cites it 24× “See Utah Code Ann. § 59-1-610 (1)(a) (1996). In other words, the court of appeals must uphold those findings of fact that are supported by substantial evidence, or "that quantum and quality of relevant evidence which is adequate to convince a reasonable mind to support a…”
Alta Pac. Assocs., Ltd. v. Utah State Tax Comm'n, 931 P.2d 103 (Utah 1997). · cites it 21× “Sevier County argues that the fee simple rule is not a rule of law, but an appraisal guideline, and the application of such guidelines is an issue of fact. Therefore, the county argues, this court must afford deference to the Commission's determination and apply "a substantial…”
Evans & Sutherland Comput. Corp. v. Utah State Tax Comm'n, 953 P.2d 435 (Utah 1997). · cites it 18× “Prior to the passage of that statute, review was in this court only and the standard of review, governed by section 59-1-610, was more restrictive. See Utah Code Ann.”
49th Street Galleria v. Tax Comm'n, Auditing Div., 860 P.2d 996 (Utah Ct. App. 1993). · cites it 16× “8 STANDARD OF REVIEW Our analysis of tax cases is guided by the standards of review announced in Utah Code Ann. § 59-1-610 (Supp.1993). OSI Indus.”
Bd. of Equalization v. Utah State Tax Comm'n Ex Rel. Benchmark, Inc., 864 P.2d 882 (Utah 1993). · cites it 15× “Utah Code Ann. § 59-1-610 (1) (Supp.1993).”
ABCO Enter. v. Utah State Tax Comm'n, 2009 UT 36 (Utah 2009). · cites it 5× “" Utah Code Ann. § 59-1-610 (1)(a) (2008). We review the Commission's conclusions of law for correctness, granting no deference where the statute at issue, as here, gives no explicit grant of discretion to the Commission.”
Utah State Tax Comm'n v. Stevenson, 2006 UT 84 (Utah 2006). · cites it 8× “3d 1232 , and a correctness standard to the ALJ's conclusions of law, see Utah Code Ann. § 59-1-610 (1)(b) (2004); Stevenson, 2005 UT App 179, ¶ 10 , 112 P.”
Harper Investments, Inc. v. Auditing Div., Utah State Tax Comm'n, 868 P.2d 813 (Utah 1994). · cites it 8× “"We grant the Commission no deference concerning its conclusions of law, applying a correction-of-error standard, unless there is an explicit grant of discretion contained in a statute at issue before the appellate court.”
Beaver Cnty. v. Utah State Tax Comm'n, 919 P.2d 547 (Utah 1996). · cites it 12× “" Utah Code Ann. § 59-1-610 (1)(b). The proceeding from which the Counties appeal was a formal adjudicative proceeding.”
Newspaper Agency Corp. v. Auditing Div. of Utah State Tax Comm'n, 938 P.2d 266 (Utah 1997). · cites it 6× “2d at 19 ; see also Utah Code Ann. § 59-1-610 (1); Utah Admin.”
T-Mobile USA, Inc. v. Utah State Tax Comm'n, 2011 UT 28 (Utah 2011). · cites it 4× “§§ 59-1-610(1), 683G-4-408(1), (4). In this case, T-Mobile chose the first avenue.”
Beaver Cnty. v. Utah State Tax Comm'n, 916 P.2d 344 (Utah 1996). · cites it 6× “” Utah Code Ann. § 59-1-610 (l)(b). The proceeding from which the Counties appeal was a formal adjudicative proceeding.”
Show all 78 citing cases →
— Utah Code § 59-1-610(1) — 7 cases
T-Mobile USA, Inc. v. Utah State Tax Comm'n, 2011 UT 28 (Utah 2011). “§§ 59-1-610(1), 683G-4-408(1), (4). In this case, T-Mobile chose the first avenue.”
Evans & Sutherland Comput. Corp. v. Utah State Tax Comm'n, 953 P.2d 435 (Utah 1997). “Prior to the passage of that statute, review was in this court only and the standard of review, governed by section 59-1-610, was more restrictive. See Utah Code Ann.”
Bd. of Equalization v. Utah State Tax Comm'n Ex Rel. Benchmark, Inc., 864 P.2d 882 (Utah 1993). “Utah Code Ann. § 59-1-610 (1) (Supp.1993).”
Anadarko Petroleum Corp. v. Utah State Tax Comm'n, 2015 UT 25 (Utah 2015).
Benjamin v. Utah State Tax Comm'n, 2011 UT 14 (Utah 2011).
— Utah Code § 59-1-610(1)(a) — 6 cases
Ivory Homes, Ltd. v. Utah State Tax Comm'n, 266 P.3d 751 (Utah 2011).
Utah State Tax Comm'n v. Stevenson, 2006 UT 84 (Utah 2006). “3d 1232 , and a correctness standard to the ALJ's conclusions of law, see Utah Code Ann. § 59-1-610 (1)(b) (2004); Stevenson, 2005 UT App 179, ¶ 10 , 112 P.”
T-Mobile USA, Inc. v. Utah State Tax Comm'n, 2011 UT 28 (Utah 2011). “§§ 59-1-610(1), 683G-4-408(1), (4). In this case, T-Mobile chose the first avenue.”
Cnty. Bd. of Equalization of Wasatch Cnty. v. Stichting Mayflower Recreational Fonds, 2000 UT 57 (Utah 2000).
Wal-Mart v. Tax Comm'n, 2025 UT App 28 (Utah Ct. App. 2025).
— Utah Code § 59-1-610(1)(b) — 15 cases
Martinez v. Media-Paymaster Plus/Church of Jesus Christ of Latter-Day Saints, 2007 UT 42 (Utah 2007).
Yeargin, Inc. v. Auditing Div. of Utah State Tax Comm'n, 2001 UT 11 (Utah 2001). “See Utah Code Ann. § 59-1-610 (1)(a) (1996). In other words, the court of appeals must uphold those findings of fact that are supported by substantial evidence, or "that quantum and quality of relevant evidence which is adequate to convince a reasonable mind to support a…”
Airport Hilton Ventures, Ltd. v. Utah State Tax Comm'n, 1999 UT 26 (Utah 1999).
Murray v. Utah Labor Comm'n, 2013 UT 38 (Utah 2013).
Alta Pac. Assocs., Ltd. v. Utah State Tax Comm'n, 931 P.2d 103 (Utah 1997). “Sevier County argues that the fee simple rule is not a rule of law, but an appraisal guideline, and the application of such guidelines is an issue of fact. Therefore, the county argues, this court must afford deference to the Commission's determination and apply "a substantial…”
— Utah Code § 59-1-610(2) — 4 cases
Yeargin, Inc. v. Auditing Div. of Utah State Tax Comm'n, 2001 UT 11 (Utah 2001). “See Utah Code Ann. § 59-1-610 (1)(a) (1996). In other words, the court of appeals must uphold those findings of fact that are supported by substantial evidence, or "that quantum and quality of relevant evidence which is adequate to convince a reasonable mind to support a…”
49th Street Galleria v. Tax Comm'n, Auditing Div., 860 P.2d 996 (Utah Ct. App. 1993). “8 STANDARD OF REVIEW Our analysis of tax cases is guided by the standards of review announced in Utah Code Ann. § 59-1-610 (Supp.1993). OSI Indus.”
Bd. of Equalization v. Utah State Tax Comm'n Ex Rel. Benchmark, Inc., 864 P.2d 882 (Utah 1993). “Utah Code Ann. § 59-1-610 (1) (Supp.1993).”
Brent Brown Dealerships v. Tax Comm'n, Motor Veh. Enf't Div., 139 P.3d 296 (Utah Ct. App. 2006).
— Utah Code § 59-1-610(l)(b) — 3 cases
Newspaper Agency Corp. v. Utah State Tax Comm'n, Auditing Div., 892 P.2d 17 (Utah Ct. App. 1995).
Mountain Ranch Estates v. Utah State Tax Comm'n, 2004 UT 86 (Utah 2004).
Nelson v. Auditing Div., Utah State Comm'n, 903 P.2d 939 (Utah 1995).
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