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RME PETROLEUM CO. v. WYOMING DEPT. OF REV.

No. 04-185, 04-190, 04-204.

150 P.3d 673 (2007)

2007 WY 16

RME PETROLEUM COMPANY, Appellant (Petitioner), v. WYOMING DEPARTMENT OF REVENUE, Appellee (Respondent). Chevron U.S.A., Inc., Appellant (Petitioner), v. Department of Revenue, State of Wyoming, Appellee (Respondent). The Louisiana Land and Exploration Company; and Burlington Resources Oil & Gas Co., LP, Appellants (Petitioners), v. Wyoming Department of Revenue; and Board of County Commissioners of the County of Fremont, Appellees (Respondents).

Supreme Court of Wyoming.

January 26, 2007.

Attorney(s) appearing for the Case

Representing Appellants RME, The Louisiana Land and Exploration Company, and Burlington Resources Oil & Gas Co. LP: Lawrence J. Wolfe, Patrick R. Day, and Walter F. Eggers, III, of Holland & Hart, LLP, Cheyenne, Wyoming. Argument by Mr. Wolfe.

Representing Appellant Chevron U.S.A., Inc.: William J. Thomson, III, Randall B. Reed, and Brian J. Hanify, of Dray, Thomson & Dyekman, P.C., Cheyenne, Wyoming. Argument by Mr. Thomson.

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

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

BURKE, J.

[¶ 1] In three consolidated appeals, RME Petroleum Company, Chevron U.S.A., Inc., Louisiana Land and Exploration Company, and Burlington Resources Oil & Gas Co., LP, ("Taxpayers"), challenge taxation and valuation determinations made by the Department of Revenue ("Department"). Taxpayers' appeals involve oil and gas production valued under the statutory proportionate profits method as stated in Wyo. Stat. Ann. § 39-14-203(b)(vi)(D).

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