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BP AMERICA PRODUCTION CO. v. DEPT. OF REV.

No. 03-191.

112 P.3d 596 (2005)

2005 WY 60

BP AMERICA PRODUCTION COMPANY; Chevron U.S.A., Inc.; and Anadarko E & P Company, LP, Appellants (Petitioners), v. DEPARTMENT OF REVENUE, STATE OF WYOMING; and Board of County Commissioners for Uinta County, Wyoming, Appellees (Respondents).

Supreme Court of Wyoming.

Rehearing Denied July 6, 2005.

Attorney(s) appearing for the Case

Representing Appellant BP America Production Company: Robert A. Swiech, John L. Bordes, Jr., and Nicole Crighton of Oreck, Bradley, Crighton, Adams & Chase, Boulder, Colorado.

Representing Appellant Chevron U.S.A., Inc.: William J. Thomson II and Randall B. Reed of Dray, Thomson & Dyekman, P.C., Cheyenne, Wyoming.

Representing Appellant Anadarko E & P Company, LP: Lawrence J. Wolfe and Walter F. Eggers, III, of Holland & Hart, LLP, Cheyenne, Wyoming; Russell W. Miller, Assistant General Counsel of Anadarko Petroleum Corp., Houston, Texas. Argument by Mr. Wolfe.

Representing Appellee Wyoming Department of Revenue: Patrick J. Crank, Wyoming Attorney General; Michael L. Hubbard, Deputy Attorney General; Karl D. Anderson, Senior Assistant Attorney General; Martin L. Hardsocg, Senior Assistant Attorney General, Cheyenne, Wyoming. Argument by Mr. Hardsocg.

Representing Appellee Board of County Commissioners of Uinta County: Bruce A. Salzburg of Freudenthal, Salzburg & Bonds, P.C., Cheyenne, Wyoming.

Before HILL, C.J., and GOLDEN, LEHMAN, KITE, and VOIGT, JJ.

GOLDEN, Justice.

[¶ 1] BP America Production Company, Chevron USA, Inc., and Anadarko E & P Co. LP ("Taxpayers") appeal a State Board of Equalization (the Board) decision upholding the Department of Revenue's (the Department) decision to use the comparable value method for determining the fair market value of their year 2000 natural gas production from the Whitney Canyon Field. See Wyo. Stat. Ann. § 39-14-203(b)(vi)(B) (LexisNexis 2003).

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