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UNION PACIFIC RESOURCES CO. v. STATE

No. 92-30.

839 P.2d 356 (1992)

UNION PACIFIC RESOURCES COMPANY, Appellant (Plaintiff), v. STATE of Wyoming; Wyoming Department of Revenue; Earl Kabeiseman, in his official capacity as Director of the Wyoming Department of Revenue; Wyoming State Board of Equalization; Wyoming Tax Commission; Nancy D. Freudenthal, Marvin Applequist, II, and C.H. Brown, III, in their official capacities as members of the Wyoming State Board of Equalization and the Wyoming Tax Commission; Wyoming Department of Audit; Roger W. Dewey, in his capacity as Director of the Wyoming Department of Audit; Board of County Commissioners of the County of Uinta; Board of County Commissioners of the County of Sweetwater; Board of County Commissioners of the County of Laramie; Board of County Commissioners of the County of Carbon; Board of County Commissioners of the County of Crook; Board of County Commissioners of the County of Lincoln; and Board of County Commissioners of the County of Converse, Appellees (Defendants), and Board of County Commissioners of the County of Albany; Board of County Commissioners of the County of Big Horn; Board of County Commissioners of the County of Campbell; Board of County Commissioners of the County of Fremont; Board of County Commissioners of the County of Goshen; Board of County Commissioners of the County of Hot Springs; Board of County Commissioners of the County of Johnson; Board of County Commissioners of the County of Natrona; Board of County Commissioners of the County of Niobrara; Board of County Commissioners of the County of Park; Board of County Commissioners of the County of Platte; Board of County Commissioners of the County of Sheridan; Board of County Commissioners of the County of Sublette; Board of County Commissioners of the County of Teton; Board of County Commissioners of the County of Washakie; and Board of County Commissioners of the County of Weston, Appellees (Defendants/Intervenors).

Supreme Court of Wyoming.

September 23, 1992.

Attorney(s) appearing for the Case

Dennis W. Lancaster of Phillips, Lancaster & Thomas, P.C., Evanston, and Cynthia M. Lummis of Wiederspahn, Lummis & Liepas, Cheyenne, for appellant.

Joseph B. Meyer, Atty. Gen., and Michael L. Hubbard, Sr. Asst. Atty. Gen., for appellee State of Wyoming.

Bruce A. Salzburg and David D. Freudenthal of Herschler, Freudenthal, Salzburg, Bonds & Rideout, P.C., Cheyenne, and Peter C. Maxfield, Laramie, for appellee Counties.

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

URBIGKIT, Justice.

This mineral tax assessment challenge was filed by a very large Wyoming corporate taxpayer in a district court declaratory judgment action. Complex issues were presented by this major oil and gas producer. The complaint named both county and state officials as defendants. As the appellant's brief states, this appeal "involves the proper method and manner in which the State, County and other named government officials * * * may value, audit, assess...

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