Opinion by Judge RICHMAN.
The Colorado Department of Revenue (the department) and Roxanne Huber, in her capacity as Executive Director of the department, appeal the judgment in favor of Noble Energy, Inc. (taxpayer) for a refund of sales taxes. We affirm in part, reverse in part, and remand for further proceedings.
I. Background
The basic facts are undisputed. Taxpayer hired oil and gas well service companies to "fracture" wells that it operated...
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