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GULF OIL CORP. v. STATE, DEPT. OF REVENUE

No. S-1985.

755 P.2d 372 (1988)

GULF OIL CORPORATION, Appellant, v. The STATE of Alaska, DEPARTMENT OF REVENUE, Appellee.

Supreme Court of Alaska.

March 25, 1988.

Attorney(s) appearing for the Case

Patrick Gilmore, Atkinson, Conway & Gagnon, Anchorage, Norman B. Barker, John H. Sharer, and Stephen L. Tolles, Gibson, Dunn & Crutcher, Los Angeles, Cal., for appellant.

David T. LeBlond, Asst. Atty. Gen., Anchorage, and Grace Berg Schaible, Atty. Gen., Juneau, for appellee.

William B. Rozell, Faulkner, Banfield, Doogan & Holmes, Juneau, Jerome R. Hellerstein, Herzfeld & Rubin, New York City, for amicus curiae Mobil Oil Corp.

Before MATTHEWS, C.J., and RABINOWITZ, BURKE, COMPTON and MOORE, JJ.

OPINION

MOORE, Justice.

In this case, we must determine the proper state tax treatment of some extraordinarily high tax payments made by Gulf Oil Corporation to Kuwait, Iran, Nigeria, Ecuador, Venezuela, and Angola (hereafter the "KINEVA" countries) — payments that amounted to nearly all of Gulf's income in those countries. We must also determine the appropriate valuation of some Alaska oil drilling leaseholds that cost up to $12 million per year...

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