concurring:
I agree that the Nevada Department of Taxation is correct in determining that the Meridian Gold Company owed additional taxes based on straight-line depreciation rather than the accelerated depreciation originally approved. However, I disagree that the phrase “mining operation” is unambiguous and clearly includes cyanide heap leaching. As the majority acknowledges, traditionally, mining involves digging into the ground and extracting precious metals. *638Cyanide heap leaching does not involve digging into the ground and extracting precious metals. The material being treated is already above the earth. Meridian closed the mine itself and concluded that its mining operation was completed.
However, considering the fact that the material being leached for precious metals was originally extracted from the mine and was an integral part of the process of gaining the precious metals, the Nevada Department of Taxation reasonably interpreted the heap leaching process to be part of a “mining operation.” As the majority indicates, this court will give deference to an administrative body’s interpretation when it is within the statutory language.1 Therefore, the judgment of the district court should be affirmed.
State ex rel. Tax Comm’n v. Saveway, 99 Nev. 626, 630, 668 P.2d 291, 294 (1983).