LOBRANO, Judge.
This case originated in the Board of Tax Appeals as a result of four assessments by the Department of Revenue (the Department) against Shell Oil, Shell Western E & P, Inc. and Shell Offshore, Inc. (Shell). Although consolidated by the Board of Tax Appeals for hearing, the four assessments involve two unrelated issues.
In proceedings numbers 3392 and 3393, the Department assessed Shell for severance taxes on natural gas production for the...
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