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N <br />NO. COA95 --1168 <br />NORTH CAROLINA COURT OF APPEALS <br />Filed: 20 August 1996 = , <br />In the matter of: <br />The appeal of Weyerhaeuser Company <br />from the decision of the Craven County <br />Board of Commissioners dated <br />8 February 1994 concerning the listing, <br />appraisal, and assessment of certain <br />property for the years 1987 through <br />1992. <br />From the North Carolina <br />Property Tax Commission <br />No. 94 PTC 59 <br />Appeal by taxpayer from order entered 2 June 1995 by the <br />North Carolina Property Tax Commission. Heard in the Court of <br />Appeals 24 May 1996. <br />C.B. McLean, Jr., for taxpayer - appellant. <br />sumrell, Bugg, Carmichael & Ashton, P.A., by James R. sugg and <br />Jimmie B. Hicks, Jr., for County - Appellee. <br />MARTIN, John C., Judge. <br />In July 1992, Craven County ( "County ") initiated an audit of <br />Weyerhaeuser Company's ( "Weyerhaeuser ") personal property tax <br />listings in the county for the tax years 1987 through 1992. On 29 <br />December 1992, the County's Tax Administrator, pursuant to G.S. § <br />105- 312(d), sent a notice of discovery to Weyerhaeuser proposing <br />taxes and penalties against the company for unlisted personal <br />property. The audit also revealed that Weyerhaeuser had not listed <br />certain pollution control equipment for the tax years 1991 and <br />1992. <br />On 10 December 1992, Weyerhaeuser filed an application with <br />the North Carolina Department of Environmental, Health and Natural <br />