ZIMMERMAN, Chief Justice:
Harken Southwest Corporation ("Harken") operates several oil and gas wells in San Juan County. In March of 1994, Harken applied to the Utah Division of Oil, Gas and Mining ("Division") for designation of thirteen wells drilled between 1990 and 1992 as "wildcat" wells. Wildcat wells drilled after January 1, 1990, are exempt from severance taxes during the first twelve months of production. Utah Code Ann. § 59-5-102(2)(d). The Division...
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