RUSSELL, Judge.
In February 1988 the Alabama Department of Revenue (Department) entered a final assessment against Phillips Petroleum Company (Phillips) for taxes purportedly due under the provisions of §§ 40-20-1 to -13 and § 9-17-25, Ala.Code 1975. Those statutes provide for the levy of a tax on oil and gas valued in their raw and untreated state at the point of production, i.e., severance from the ground at the mouth of the well. The Department's...
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