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CHESAPEAKE OPERATING v. DEP'T OF REVENUE

S-23-0036.

537 P.3d 1134 (2023)

2023 WY 107

CHESAPEAKE OPERATING, LLC, Appellant (Petitioner), v. State of Wyoming, DEPARTMENT OF REVENUE, Appellee (Respondent).

Supreme Court of Wyoming.

November 7, 2023.

Attorney(s) appearing for the Case

Representing Appellant: Walter F. Eggers III and Kasey J. Schlueter , Holland & Hart LLP, Cheyenne, Wyoming. Argument by Mr. Eggers.

Representing Appellee: Bridget Hill , Wyoming Attorney General; Brandi Monger , Deputy Attorney General; Karl D. Anderson , Supervising Attorney General; James Peters , Senior Assistant Attorney General. Argument by Mr. Peters.

Before FOX, C.J., and KAUTZ, BOOMGAARDEN, GRAY, and FENN, JJ.

[¶1] The Wyoming Departments of Audit and Revenue (Department) conducted a mineral tax audit of Chesapeake Operating, LLC's (Chesapeake) oil and gas production for the production years 2010-2012 and 2014-2016. It issued audit assessments increasing the value of Chesapeake's production based on a point of valuation downstream...

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