A. Standard of Review Where the district court conducts a trial de novo pursuant to Idaho Code § 63–3812(c) in an appeal from a BTA decision, this Court defers to the district court's findings of facts that are supported by substantial evidence, but exercises free review over the district court's conclusions of law. Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 419–20, 247 P.3d 644, 646–47 (2011) ; Canyon Cnty. Bd. of Equalization v. Amalgamated Sugar Co., LLC, 143 Idaho 58, 60, 137 P.3d 445, 447 (2006). The interpretation of a statute is a question of law over which we exercise free review.

Thus, "this Court defers to the district court's findings of fact that are supported by substantial evidence, but exercises free review over the district court's conclusions of law." Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 420, 247 P.3d 644, 647 (2011) (quoting Canyon Cnty. Bd. of Equalization v. Amalgamated Sugar Co., 143 Idaho 58, 60, 137 P.3d 445, 447 (2006) ). When reviewing a grant of summary judgment, this Court employs the same standard as the district court.

The interpretation of a statute is a question of law over which this Court exercises free review. Williams v. Idaho State Bd. of Real Estate Appraisers, 157 Idaho 496, 502, 337 P.3d 655, 661 (2014) (quoting Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 420, 247 P.3d 644, 647 (2011)). This Court may set aside the agency’s decision if it determines the agency erred in a manner specified in Idaho Code section 67-5279(3)(a)-(e) and that "a substantial right of the a challenging party has been prejudiced."

By establishing that its valuation was more likely accurate than not, the County met its burden to establish that the BTA's valuation decision was erroneous. A market value conclusion is erroneous if it "fails to reflect the fair market or full cash value of the property." SeeKimbrough v. Idaho Bd. of Tax Appeals , 150 Idaho 417, 422, 247 P.3d 644, 649 (2011). A "preponderance of the evidence" is evidence that, when weighed with that opposed to it, has more convincing force and from which results a greater probability of truth.

"The interpretation of a statute is a question of law subject to free review." Kimbrough v. Idaho Bd. of Tax Appeals , 150 Idaho 417, 420, 247 P.3d 644, 647 (2011). However, the determination of when an action accrues for purposes of the statute of limitations, "may be a question of law or a question of fact, depending upon whether any disputed issues of material fact exist" Kimbrough v. Reed , 130 Idaho 512, 516, 943 P.2d 1232, 1236 (1997).

"The interpretation of a statute is a question of law subject to free review." Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 420, 247 P.3d 644, 647 (2011). However, the determination of when an action accrues for purposes of the statute of limitations, "may be a question of law or a question of fact, depending upon whether any disputed issues of material fact exist."

"Administrative rules are interpreted the same way as statutes."Rangen, Inc. v. Idaho Dep’t of Water Res. , 160 Idaho 251, 256, 371 P.3d 305, 310 (2016) (quoting Kimbrough v. Idaho Bd. of Tax Appeals , 150 Idaho 417, 420, 247 P.3d 644, 647 (2011) ). Therefore, when considering an administrative rule,

" Kimbrough v. Idaho Bd. of Tax Appeals , 150 Idaho 417, 419–20, 247 P.3d 644, 646–47 (2011) (citations omitted). "Interpretations of requirements for charitable exemption from property tax are questions of law over which this Court exercises free review."

Administrative rules are interpreted the same way as statutes." Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 420, 247 P.3d 644, 647 (2011). A plain reading of CMR 43.03 suggests that the Director's consideration of potential injury to other water users is discretionary.

"The interpretation of a statute is a question of law subject to free review." Kimbrough v. Idaho Bd. of Tax Appeals, 150 Idaho 417, 420, 247 P.3d 644, 647 (2011). "As this is an appeal from a district court's decision, we review the district court's decision as a matter of procedure."