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WPX ENERGY ROCKY v. WYO. DEP'T OF REVENUE

S-21-0269 S-21-0275.

516 P.3d 449 (2022)

2022 WY 104

WPX ENERGY ROCKY MOUNTAIN, LLC, Appellant (Petitioner), v. WYOMING DEPARTMENT OF REVENUE, Appellee (Respondent). Wyoming Department of Revenue, Appellant (Cross-Petitioner), v. WPX Energy Rocky Mountain, LLC, Appellee (Cross-Respondent).

Supreme Court of Wyoming.

August 24, 2022.

Attorney(s) appearing for the Case

Representing WPX Energy Rocky Mountain, LLC: Walter F. Eggers III and Kasey J. Schlueter , Holland & Hart LLP, Cheyenne, Wyoming. Argument by Mr. Eggers.

Representing Wyoming Department of Revenue: Bridget Hill , Attorney General; Brandi Monger , Deputy Attorney General; Karl D. Anderson , Supervising Attorney General; James Peters , Senior Assistant Attorney General. Argument by Mr. Peters.

Before FOX, C.J., and KAUTZ, BOOMGAARDEN, GRAY, and FENN JJ.

[¶1] These consolidated appeals concern whether and to what extent WPX Energy Rocky Mountain, LLC (WPX) is entitled to deduct a certain type of expense known as a "reservation fee" under the "netback" severance tax valuation method, Wyo. Stat. Ann. § 39-14-203(b)(vi)(C) (LexisNexis 2021), for natural gas production...

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