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STATE, DEPT. OF REVENUE v. PARSONS CORP.

No. S-4137.

843 P.2d 1238 (1992)

STATE of Alaska, DEPARTMENT OF REVENUE, Appellant, v. The PARSONS CORPORATION and The Ralph M. Parsons Company, Appellees.

Supreme Court of Alaska.

December 31, 1992.

Attorney(s) appearing for the Case

Marilyn May, Teresa Williams, David T. Leblond, Asst. Attys. Gen., Anchorage, Charles E. Cole, Atty. Gen., Juneau, for appellant.

Lance B. Gordon, Patrick G. Woosley, Pasadena, CA, David G. Shaftel, Anchorage, for appellees.

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

OPINION

BURKE, Justice.

The Alaska Department of Revenue ("DOR") appeals the superior court's reversal of DOR's July 5, 1988, administrative decision affirming the audit division's assessment of corporate income taxes against the Parsons Corporation and the Ralph M. Parsons Company ("Parsons") for tax years 1977 through 1981. At issue is the proper allocation of revenue derived from contracts to construct oil and gas facilities at Prudhoe Bay under the three...

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