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TRAVELOCITY.COM v. WYOMING DEPT. OF REVENUE

No. S-13-0078.

329 P.3d 131 (2014)

2014 WY 43

TRAVELOCITY.COM LP, Priceline.Com Incorporated, Hotels.Com, LP, Hotwire, Inc., Expedia, Inc., Orbitz, LLC, and Trip Network, Inc. (d/b/a Cheaptickets.Com), Appellants (Petitioners), v. WYOMING DEPARTMENT OF REVENUE, Appellee (Respondent).

Supreme Court of Wyoming.

April 3, 2014.

Attorney(s) appearing for the Case

Representing Appellants: Lawrence J. Wolfe , P.C., and Brynn A. Hvidston of Holland & Hart, LLP, Cheyenne, Wyoming; Jeffrey A. Rossman of McDermott Will & Emery LLP, Chicago, Illinois. Argument by Mr. Rossman.

Representing Appellee: Peter K. Michael , Wyoming Attorney General; Martin L. Hardsocg , Deputy Attorney General; Cathleen D. Parker , Senior Assistant Attorney General. Argument by Ms. Parker.

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

DAVIS, Justice.

[¶ 1] Appellee Wyoming Department of Revenue (Department) directed Appellants, which are on-line travel companies (OTCs), to collect and remit tax on the total amounts they collected from customers booking hotel rooms in Wyoming. Appellants appealed the order to the State Board of Equalization (SBOE), which upheld it. The OTCs petitioned the First Judicial District Court for review, and it certified the case to this Court, which accepted the certification...

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