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DEPT. OF REVENUE v. ATLANTIC RICHFIELD

No. S-4820.

858 P.2d 307 (1993)

STATE of Alaska, DEPARTMENT OF REVENUE, Appellant, v. ATLANTIC RICHFIELD COMPANY and Combined Subsidiaries, Appellee.

Supreme Court of Alaska.

Rehearing Denied and Motion for Clarification Granted October 29, 1993.

Attorney(s) appearing for the Case

Ellen Toll, Asst. Atty. Gen., Anchorage, Charles E. Cole, Atty. Gen., Juneau, for appellant.

Robert E. McManus, Peter J. Turner, ARCO Alaska, Inc., Anchorage, and William B. Rozell, Mala J. Reges, Faulkner, Banfield, Doogan & Holmes, Juneau, for appellee.

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

OPINION

MATTHEWS, Justice.

I. INTRODUCTION

This case concerns the tax liability of Atlantic Richfield Company and Combined Subsidiaries ("ARCO") for the years 1978-81 under two sections of AS 43.21, the Alaska Oil and Gas Corporate Income Tax (repealed effective January 1, 1982). Two distinct issues are presented on appeal. The first issue, the Trans Alaska Pipeline System ("TAPS") interest issue, involves the interpretation of AS 43.21...

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