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  5. 876 P.2d 719 (1993)
 

PHILLIPS PETROLEUM CO. v. OKLAHOMA TAX COM'N

No. 79284.

876 P.2d 719 (1993)

PHILLIPS PETROLEUM COMPANY, Union Pacific Resources Company, (Formerly Champlin Petroleum Company), TXO Production Corp., Koch Industries, Inc., and Citgo Petroleum Corporation, Appellees/Counter-Appellants, v. The OKLAHOMA TAX COMMISSION, and Robert E. Anderson, Robert L. Wadley, and Don W. Kilpatrick, Members of the Oklahoma Tax Commission, Appellants/Counter-Appellees.

Court of Appeals of Oklahoma, Division No. 3.

As Modified on Limited Grant of Rehearing; Rehearing Otherwise Denied February 1, 1994.

As Modified on Limited Grant of Certiorari May 31, 1994.

Attorney(s) appearing for the Case

David Hudson, Gen. Counsel, Kathryn Bass, Asst. Gen. Counsel, Oklahoma Tax Com'n, Oklahoma City, for appellants/counter-appellees.

Clyde A. Muchmore, Kelley C. Callahan, Harvey D. Ellis, Crowe & Dunlevy, Oklahoma City, for appellees/counter-appellants.

Released for Publication by Order of the Court of Appeals of Oklahoma, Division No. 3.

OPINION

BAILEY, Presiding Judge:

The Oklahoma Tax Commission (Commission) seeks review of an order of the Trial Court granting partial summary judgment to Phillips Petroleum Company, Union Pacific Resources Company, TXO Production Corporation, Koch Industries, Inc., and Citgo Petroleum Corporation (collectively...

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