OPINION
CASTILLO, Judge.
{1} In this appeal we interpret statutes relating to taxation of natural gas. Appellants (Producers) are producers of conventional gas and coal seam gas in the San Juan Basin in New Mexico. They appeal from summary judgments affirming New Mexico Taxation & Revenue Department (TRD) denials of requests for refunds of the Natural Gas Processor's Tax (NGPT). Producers argue: (1) the removal of carbon dioxide from coal seam...
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