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  5. 832 S.E.2d 135 (2019)
 

STEAGER v. CONSOL ENERGY, INC.

Nos. 18-0121, No. 18-0122, No. 18-0123, No. 18-0124, No. 18-0125, No. 18-0227, No. 18-0228.

832 S.E.2d 135 (2019)

Dale W. STEAGER, West Virginia State Tax Commissioner, Respondent Below/Petitioner v. CONSOL ENERGY, INC., d/b/a CNX Gas Company LLC, Petitioner Below/Respondent and Dale W. Steager, West Virginia State Tax Commissioner, Respondent Below/Petitioner v. Consol Energy, Inc., d/b/a CNX Gas Company LLC, Petitioner Below/Respondent and Dale W. Steager, West Virginia State Tax Commissioner and David E. Sponaugle, Assessor of Doddridge County, Respondents Below/Petitioners v. Consol Energy, Inc., d/b/a CNX Gas Company LLC, Petitioner Below/Respondent and Dale W. Steager, West Virginia State Tax Commissioner and Arlene Mossor, Assessor of Ritchie County, Respondents Below/Petitioners v. Antero Resources Corporation, Petitioner Below/Respondent and Dale W. Steager, West Virginia State Tax Commissioner and David E. Sponaugle, Assessor of Doddridge County, Respondents Below/Petitioners v. Antero Resources Corporation, Petitioner Below/Respondent and The County Commission of Doddridge County, Sitting as the Board of Assessment Appeals and Board of Equalization, Respondent Below/Petitioner v. Consol Energy, Inc., d/b/a CNX Gas Company LLC, Petitioner Below/Respondent and The County Commission of Doddridge County, Sitting as the Board of Assessment Appeals and Board of Equalization, Respondent Below/Petitioner v. Antero Resources Corporation, Petitioner Below/Respondent.

Supreme Court of Appeals of West Virginia.

Filed: June 5, 2019.

Attorney(s) appearing for the Case

Patrick Morrisey , Attorney General, L. Wayne Williams Esq. , Assistant Attorney General, Charleston, WV, Counsel for Petitioner Dale W. Steager, West Virginia State Tax Commissioner.

Jonathan Nicol, Esq. , Brandy D. Bell, Esq. , Lindsay M. Gainer, Esq. , Kay Casto & Chaney PLLC, Charleston, WV, Counsel for Respondent the County Commission, of Doddridge County.

James Brian Shockley, Esq. , Assistant Prosecuting Attorney, Harrison County Prosecutor's Office, Clarksburg, WV, Counsel for Amicus Curiae the Harrison, County Commission and Joseph R. Romano, Assessor of Harrison County.

Jack C. McClung, Esq. , Charleston, WV, Counsel for Amicus Curiae West Virginia Association of County Officials, Inc.

Kelli D. Talbott, Esq. , Senior Deputy Attorney General, Charleston, WV, Counsel for Amicus Curiae Steven L. Paine, West Virginia State Superintendent of Schools.

Timothy E. Haught, Esq. , Wetzel County Prosecuting Attorney, New Martinsville, WV, Counsel for Amicus Curiae the County, Commission of Wetzel County, West Virginia.

Ancil G. Ramey, Esq. , Steptoe & Johnson PLLC, Huntington, WV, Craig A. Griffith, Esq , John J. Meadows, Esq. , Steptoe & Johnson PLLC, Charleston, WV, Counsel for Respondents, Consol Energy Inc. d/b/a CNX Gas, Company LLC and Antero, Resources Corporation.

These are seven consolidated appeals from the business court's January 17, 2018 and February 7, 2018, orders reversing various Boards of Assessment Appeals and rejecting the West Virginia State Tax Department's valuation of respondents' gas wells for ad valorem tax purposes. The business court concluded that the Tax Department...

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