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EL PASO NATURAL GAS CO. v. STRAYHORN

No. 06-05-00059-CV.

208 S.W.3d 676 (2006)

EL PASO NATURAL GAS COMPANY, Appellant, v. Carole Keeton STRAYHORN, Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas, Appellees.

Court of Appeals of Texas, Texarkana.

Decided October 18, 2006.

Rehearing Overruled December 19, 2006.

Attorney(s) appearing for the Case

Ray Langenberg, Scott, Douglass & McConnico, LLP, Austin, Appellant.

Jim B. Cloudt, Assistant Atty. Gen., Austin, for Appellees.

Before MORRISS, C.J., ROSS and CARTER, JJ.

OPINION

Opinion by Chief Justice MORRISS.

El Paso Natural Gas Company (the Company) and the Texas Comptroller of Public Accounts battle over the Company's franchise tax liability for the years 1989 through 1991, in a protracted conflict with possibly millions of dollars at stake. The battlefield is littered with accounting and procedural details and is mined with obscure and often unclear statutes and agency rules.

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