In State Dept. of Revenue and Taxation v. Pacificorp, 872 P.2d 1163, 1169 (Wyo. 1994), taxpayers sought a declaratory judgment regarding rules the State Department of Revenue and Taxation promulgated "pertaining to the ad valorem tax exemption for pollution control property, claiming that the State exceeded its statutory authority when it promulgated the rules." The rules took effect in February 1992, and the taxpayers filed for declaratory relief in June 1992. Id. The taxpayers acknowledged that the tax exemption issues were "'not the subject of a direct dispute in the 1992 valuation determination,'" but argued that the "'threat of harm and improper taxation was present and real'" and that "a justiciable controversy existed because they may apply in the future for the exemption . . . and the State may deny the request." Id. at 1168. The Court concluded that no justiciable controversy existed.