Sterling Drilling Co. v. Kansas Department of Revenue

Bullock, J.:

Sterling Drilling is in the business of drilling wells. Among others, it drills wells for natural gas storage and salt water disposal. As a result of Sterling’s services in drilling these wells, the State Board of Tax Appeals assessed Sterling $154,146 in sales taxes and penalties. Sterling appealed to the district court which reversed the Board, holding Sterling’s services were excluded from sales tax under what is now K.S.A. 1982 Supp. 79-3603(p). The State appeals.

We should note, preliminarily, the appropriate scope of judicial review. Two rules are applicable:

1. “A district…