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CHEVRON U.S.A. v. DEPARTMENT OF REVENUE

No. 06-50.

154 P.3d 331 (2007)

2007 WY 43

CHEVRON U.S.A., INC., Appellant (Petitioner), v. DEPARTMENT OF REVENUE, State of Wyoming, Appellee (Respondent).

Supreme Court of Wyoming.

March 14, 2007.

Attorney(s) appearing for the Case

Representing Appellant: William J. Thomson II, Randall B. Reed, Brian J. Hanify, and Gregory C. Dyekman of Dray, Thomson & Dyekman, P.C., Cheyenne, Wyoming. Argument by Mr. Dyekman.

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

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

KITE, Justice.

[¶ 1] The State Board of Equalization (SBOE) denied Chevron U.S.A., Inc.'s (Chevron) appeal from a notice of valuation (NOV) for its Carter Creek natural gas production, concluding it had no jurisdiction because the appeal was filed more than thirty days after the Department of Revenue (DOR) decision was postmarked, in contravention of Wyo. Stat. Ann. § 39-14-209(b)(iv) (LexisNexis 2005).1 Chevron claimed the state...

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