with whom Becker, C. J., and Douglas, J., agree, dissenting:
Only taxpayers, not counties, may sue to challenge the decisions of the State Board of Equalization under the Legislature’s specific statutory scheme to equalize the value of real property.
Nevada’s Constitution directs the Legislature to “provide by law for a uniform and equal rate of assessment and taxation, and shall prescribe such regulations as shall secure a just valuation for taxation of all [real property].”1 Accordingly, the Legislature adopted NRS Chapter 361 to provide for the assessment and equalization of the value of real property. That statutory scheme specifies the timing and procedures for valuing real property for tax purposes beginning with initial determinations by each county assessor. Taxpayers who claim inequity or erroneous valuation of their property may appeal the county assessor’s valuation to the county board of equalization.2 The taxpayer or the county assessor may thereafter appeal the county board’s decision to the State Board of Equalization.3
Contrary to the majority’s claim that the right of appeal statutes do not abrogate or limit the rights of property holders to appeal, the Legislature imposes several requirements for a taxpayer to seek judicial review of the State Board of Equalization decision. To challenge the findings of the State Board of Equalization,4 the *539taxpayer must pay and protest any disputed taxes.5 In any action in district court, the taxpayer bears the burden to show by clear and satisfactory evidence that any valuation established by the county assessor, county board of equalization or State Board of Equalization is unjust and inequitable.6 This burden is deemed to create the presumption that the valuation placed on the property is reasonable.7
Nowhere in this statutory scheme, however, does the Legislature grant authority to a county to seek judicial review of State Board of Equalization decisions. When intended, the Legislature has expressly enumerated the appeal rights of a county. When the Legislature is silent, this court should not “ ‘fill in alleged legislative omissions based on conjecture as to what the legislature would of should have done.’”8 As noted, the Legislature has expressly granted the county assessor the right to appeal decisions of the county board of equalization to the State Board of Equalization.9 In NRS Chapter 360, a related chapter on taxation, the Legislature has determined that where a county is a party and is aggrieved by the decision of the Nevada Tax Commission, it may seek judicial review.10 The Legislature’s silence on the County’s right to appeal in this instance cannot be viewed as an expression of its intention to grant such a right.
The County relies on NRS 233B. 130(1) for authority to seek judicial review. I disagree for three reasons.
First, NRS 233B. 130(1) declares that any aggrieved party can seek judicial review of a final decision of an administrative agency. Therefore, if the County can rely on this statute for authority to seek judicial review, then the taxpayer should be able to do so as well. But, as noted, the Legislature has imposed a number of requirements on the taxpayer before seeking judicial review that are not present in NRS 233B. 130(1). Accepting the County’s interpretation of NRS 233B. 130(1) would lead to an absurd result that violates the canon of statutory construction that requires statutes to be read in harmony but promotes the use of a specific statute *540over that of a general statute where they pertain to the same topic.11 Under the County’s view, either we must accept that NRS 233B. 130(1) applies to only one party, the County, or we must allow the taxpayer to rely on the same provision and avoid the onerous burden of proof and the necessity to protest and pay taxes as a condition to appeal.
Second, a proper application of the rule of statutory construction, that specific statutes dealing with a subject matter take precedence over statutes of general application, shows that NRS 233B. 130(1) does not apply. That rule of statutory construction provides that a special provision dealing with a particular subject is controlling and preferred to a provision relating only in general terms to the same subject.12 There can be little question that NRS Chapter 361 deals expressly and in detail with the procedures for determining the assessment and valuation of real property. The provisions of the Administrative Procedure Act (APA), at most, supplement NRS Chapter 3 61.13 The statutory scheme of NRS Chapter 361 creates a very specific process for resolving inequity and valuation questions including the imposition of an onerous burden of proof on the taxpayer. If the APA were controlling on the issue of judicial review, the statutory procedures and evidentiary burdens in NRS Chapter 361 would be abrogated.
Finally, this court has previously held that where the APA departs from a specific statutory scheme, the specific scheme controls. In Sierra Life Insurance Co. v. Rottman, we concluded that NRS 680A.190, giving the Commissioner of Insurance authority to summarily revoke a certificate of authority, took precedence over NRS 233B.020, which requires an agency to provide notice and an opportunity to be heard to show compliance to the licensee before revocation.14
The majority also points to policy reasons to support its decision. In construing statutes, this court’s objective is to give effect to the Legislature’s intent.15 When the language of the statute is ambiguous or silent on a particular issue, it should be construed in accordance with what “reason and public policy would indicate the legislature intended.”16 The policies cited by the majority ignore the fact that counties are subordinate instrumentalities created by the State to exercise such governmental powers as are entrusted to *541them.17 The Legislature did not entrust the County with authority to challenge State Board of Equalization decisions. Further, subordinate government entities lack Fourteenth Amendment due process rights.18 Therefore, the County is not entitled to remedy an alleged error in an adverse ruling of the State Board of Equalization in the absence of a specific statutory grant of authority to appeal. If this court must consider public policy to decide this case, we should conclude that it is contrary to public policy, and thus contrary to the Legislature’s intent, to compel a taxpayer to defend a favorable decision from the State Board of Equalization against a county appeal.
Nev. Const. art. 10, § 1(1).
NRS 361.356(1); NRS 361.357(1).
NRS 361.360(1).
NRS 361.410(1).
NRS 361.420(1), (2).
NRS 361.410(2); NRS 361.430.
Pittsburg Silver Peak v. Tax Commission, 49 Nev. 46, 52, 235 P. 643, 644 (1925); Washoe County v. Golden Road Motor Inn, 105 Nev. 402, 406, 777 P.2d 358, 360 (1989); Imperial Palace v. State, Dep’t Taxation, 108 Nev. 1060, 1066, 843 P.2d 813, 817 (1992); Sun City Summerlin v. State, Dep’t Tax., 113 Nev. 835, 842, 944 P.2d 234, 238 (1997).
Falcke v. Douglas County, 116 Nev. 583, 589, 3 P.3d 661, 665 (2000) (quoting McKay v. Board of Cty. Comm’r, 103 Nev. 490, 492, 746 P.2d 124, 125 (1987)).
NRS 361.360(1).
NRS 360.245(7).
W. R. Co. v. City of Reno, 63 Nev. 330, 337, 172 P.2d 158, 161 (1946).
Id.
NRS 233B.020(2).
95 Nev. 654, 656, 601 P.2d 56, 57-58 (1979).
Davenport v. Comstock Hills — Reno, 118 Nev. 389, 392 n.4, 46 P.3d 62, 64 n.4 (2002).
Id. (internal quotation marks omitted).
First Nat. Bk. of S.F. v. Nye Co., 38 Nev. 123, 134-35, 145 P. 932, 936 (1914); Reynolds v. Sims, 377 U.S. 533, 575 (1964).
City of Boulder City v. State of Nevada, 106 Nev. 390, 392, 793 P.2d 845, 846 (1990); State ex rel. List v. County of Douglas, 90 Nev. 272, 280, 524 P.2d 1271, 1276 (1974) (stating that a county may not invoke proscriptions of the Fourteenth Amendment against the will of its creator, the State).