Union Oil Co. v. Utah State Tax Commission

WILKINS, Justice:

INTRODUCTION

T1 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

4 2 In 1997, Unocal filed for a refund of the severance taxes it paid for the years 1994 through 1997. The Commission paid the refund, then sent it to the Auditing Divigion to be audited. The Auditing Division determined that the original tax filings were…