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BHP PETROLEUM CO., INC. v. STATE

No. 89-141.

784 P.2d 621 (1989)

BHP PETROLEUM COMPANY, INC., a Delaware corporation, Appellant (Plaintiff), v. STATE of Wyoming, Wyoming Tax Commission and its members, Shirley Wittler, Carrol Orrison and Thomas E. Trowbridge in their official capacities and the Department of Revenue and Taxation, State of Wyoming, Appellees (Defendants).

Supreme Court of Wyoming.

December 29, 1989.

Attorney(s) appearing for the Case

William J. Thomson, II of Dray, Madison & Thomson, P.C., Cheyenne and John C. Siegesmund of Parcel, Mauro, Hultin & Spaanstra, Denver, Colo., for appellant.

Joseph B. Meyer, Atty. Gen., Michael L. Hubbard, Sr. Asst. Atty. Gen., for appellees.

Morris R. Massey of Brown & Drew, Casper for W.A. Moncrief, Jr. as amicus curiae.

Before CARDINE, C.J., and THOMAS, URBIGKIT, MACY and GOLDEN, JJ.

URBIGKIT, Justice.

A statutory construction issue, singularly important to Wyoming oil and gas producers and the Wyoming Department of Revenue and Taxation, is presented for consideration of the severance tax liability of the unit operator defined to be the "person extracting" for production from the Madden Deep Unit as a unitized field.1 Appellant, BHP Petroleum Company, Inc. (unit operator)...

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