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STATE v. UNION OIL CO. OF CALIFORNIA

2950830.

686 So.2d 284 (1996)

STATE of Alabama v. UNION OIL COMPANY OF CALIFORNIA.

Court of Civil Appeals of Alabama.

November 8, 1996.

Attorney(s) appearing for the Case

Jeff Sessions, Atty. Gen.; Ron Bowden, Asst. Atty. Gen. and Chief Counsel, Department of Revenue; and Claude E. Patton, Asst. Atty. Gen. and Asst. Counsel, Department of Revenue, for Appellant.

Rae M. Crowe and Duane A. Graham of Armbrecht, Jackson, DeMouy, Crowe, Holmes & Reeves, L.L.C., Mobile, for Appellee.

MONROE, Judge.

The State appeals from an order granting an oil and gas severance tax refund to Union Oil Company. The procedural history of this case is quite lengthy; however, a statement of that history is necessary for an understanding of the issues presented for review.

In September 1991, Unocal Exploration Corporation, now the Union Oil Company of California ("Union Oil"), filed a petition with the State Oil and Gas Board of Alabama ("Board"), requesting...

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