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' 9 <br />-3- <br />The dispositive issue in this appeal is whether the pollution <br />abatement equipment listed by appellant in 1991, and for which no <br />exemption was applied for in that year, should now be treated as <br />"discovered property" entitling appellant to an exemption for taxes <br />already paid on the equipment. We hold that it should not be so <br />treated. <br />"Discovered property" is defined by G.S. § 105- 273(6a) as: <br />a. Property that was not listed during a <br />listing period. <br />b. Property that was listed but the listing <br />included a substantial understatement. <br />C. Property that has been granted an <br />exemption or exclusion and does not qualify <br />for the exemption or exclusion. <br />The parties' stipulations in this case make clear that appellant <br />listed the contested pollution abatement equipment in tax year <br />1991, that the equipment was correctly valued, and that appellant <br />was assessed and paid taxes on the equipment in tax year 1991. <br />Thus, the contested equipment does not meet the statutory <br />definition of "discovered property." <br />Nevertheless, the crux of appellant's claim is that, because <br />the County's "discovery" audit revealed in 1992 that appellant <br />listed and paid taxes in 1991 on the now contested pollution <br />abatement equipment without seeking exclusion or exemption in that <br />year, it was entitled to seek exclusion in 1992 and have the listed <br />property treated as "discovered." Consequently, appellant claims <br />the Commission erred in dismissing its appeal because it had <br />