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AMOCO PROD. CO. v. STATE BD. OF EQUAL.

Nos. 98-66, 98-67.

12 P.3d 668 (2000)

AMOCO PRODUCTION COMPANY and Amoco Rocmount, Appellants (Petitioners), v. WYOMING STATE BOARD OF EQUALIZATION; Dennis W. Tippets, in his official capacity as acting chairman, Board of Equalization; and Marvin Applequist, in his official capacity as a member of the Board of Equalization, Appellees (Respondents). Amoco Production Company and Amoco Rocmount, Appellants (Petitioners), v. Wyoming State Board of Equalization; Dennis W. Tippets, in his official capacity as acting chairman, Board of Equalization; and Marvin Applequist, in his official capacity as a member of the Board of Equalization, Appellees (Respondents).

Supreme Court of Wyoming.

April 10, 2000.

Attorney(s) appearing for the Case

Representing Appellants: Algirdas Liepas of Wiederspahn, Liepas & Reese, P.C., Cheyenne, Wyoming; and John L. Bordes, Jr., Denver, Colorado.

Representing Appellees: William U. Hill, Attorney General; Michael L. Hubbard, Deputy Attorney General; and Kathleen A. "Cindy" Lewis, Special Assistant Attorney General, Cheyenne, Wyoming.

Representing Board of County Commissioners of Uinta County, Wyoming, Amicus Curiae: Bruce A. Salzburg of Herschler, Freudenthal, Salzburg, Bonds & Zerga, P.C., Cheyenne, Wyoming; and Thomas E. Barnes, Uinta County Attorney, Evanston, Wyoming.

Before LEHMAN, C.J., and THOMAS, MACY, GOLDEN, and TAYLOR, JJ.

THOMAS, Justice.

The question before this Court involves the tension between the statutory functions assigned to the Department of Revenue (the Department) and those assigned to the Board of Equalization (the Board) in the context of an appeal to the Board from a final decision of the Department pursuant to Wyo. Stat. Ann. § 39-1-304 (Michie 1997).1 The primary problem is presented by the departure of the Board from its role of reviewing...

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