In CIG Exploration, Inc. v. Utah State Tax Commission, 897 P.2d 1214, 1216 (Utah 1995), the Court held that taxpayers were not entitled to a refund under section 59-2-1321 when they paid property taxes "on the basis of a valuation that was correct as of a given January 1st," even when a subsequent federal agency decision reduced a property's revenue, making the original valuation inaccurate. Such an occurrence, the Court reasoned, did not constitute a tax "erroneously or illegally collected within the meaning of section 59-2-1321." Id.