GOLDEN, Justice.
[¶ 1] In 1997 and 1998, Appellant Wyodak Resources Development (Wyodak) filed amended coal production reports with the State of Wyoming Department of Revenue (DOR) and requested refunds of severance taxes for the years 1992 through 1995. The DOR denied those refunds, and Wyodak appealed to the State of Wyoming Board of Equalization (Board), requesting both a contested case hearing pursuant to Wyo. Stat. Ann. § 39-14-109(b), and a petition...
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