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AMOCO PRODUCTION CO. v. HAKALA

No. 5621.

644 P.2d 785 (1982)

AMOCO PRODUCTION COMPANY, Rocky Mountain Oil and Gas Association (R.M.O.G.A.), acting through its Wyoming Division, the Petroleum Association of Wyoming; Champlin Petroleum Company; Chevron USA, Inc.; Gulf Oil Corporation; Marathon Oil Company; Mountain Fuel Supply Company; Wexpro Company; True Oil Company; Burton Hawkes, Inc.; Kirkwood Oil and Gas; Edward M. Boland; Steve C. Champlin; Robert E. Hudson; and Douglas R. Dow, Appellants (Petitioners), v. R.A. HAKALA, Rudolph G. Anselmi and Doran Lummis, acting as the Wyoming State Board of Equalization, Wyoming State Tax Commission; and James E. Petry, Director of Revenue of the Department of Revenue and Taxation, Appellees (Respondents).

Supreme Court of Wyoming.

May 7, 1982.

Attorney(s) appearing for the Case

John A. Sundahl and Julie Nye Tiedeken of Godfrey & Sundahl, Cheyenne, for appellant Amoco Production Co.

W.H. Brown and Claude W. Martin of Brown, Drew, Apostolos, Massey & Sullivan, Casper, for appellants Rocky Mountain Oil and Gas Ass'n, acting through its Wyoming Division, the Petroleum Ass'n of Wyoming, Champlin Petroleum Co., Chevron USA, Inc., Gulf Oil Corp., Marathon Oil Co., Mountain Fuel Supply Co., Wexpro Co., True Oil Co., Burton/Hawkes, Inc., Kirkwood Oil and Gas, Edward M. Boland, Steve C. Champlin, Robert E. Hudson, and Douglas R. Dow.

Steven F. Freudenthal, Atty. Gen., and Ron Arnold, Asst. Atty. Gen., Cheyenne, for appellees.

Before ROSE, C.J., and RAPER, THOMAS, ROONEY and BROWN, JJ.

BROWN, Justice.

This is an appeal from a district court order affirming an interpretive ruling by the Board of Equalization (Board) that § 39-6-302(g), W.S. 1977, Cum.Supp. 1981, should be computed on oil and gas production from and after January 1, 1981.

We will affirm.

Under § 39-6-302(a) and (b), W.S. 1977, appellants were paying a severance tax of four percent on petroleum extraction. On February 28, 1981, the Governor signed an act to...

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