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UNOCAL v. TAX COMMISSION

No. 20080068.

222 P.3d 1158 (2009)

2009 UT 78

UNION OIL COMPANY OF CALIFORNIA, Petitioner, v. UTAH STATE TAX COMMISSION, Respondent.

Supreme Court of Utah.

December 8, 2009.

Attorney(s) appearing for the Case

David J. Crapo, Layne T. Smith, Salt Lake City, for petitioner.

Mark L. Shurtleff, Att'y Gen., Clark L. Snelson, Asst. Att'y Gen., Salt Lake City, for respondent.

INTRODUCTION

WILKINS, Justice:

¶ 1 The Union Oil Company of California (Unocal) petitioned this court for review of a Utah State Tax Commission (Tax Commission) decision holding that Unocal was not entitled to a refund of severance tax payments. We affirm the decision of the Tax Commission in part and reverse in part.

PROCEDURAL BACKGROUND

¶ 2 In 1997, Unocal filed for a refund of the severance taxes it paid for the years 1994...

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