Petra Energy, Inc. v. Department of Revenue

MACY, Justice.

Appellants Petra Energy, Inc. and Asher Associates, Inc. petitioned the district court for a review of the State Board of Equalization's decision concluding that Appellee Department of Revenue had a valid lien against the appellants' oil and gas interests in Niob-rara County. The district court certified the case to this Court pursuant to W.R.A.P. 12.09(b).

We reverse.

ISSUE

The appellants present a single issue for our review:

Does a lien for severance tax and aceru-ing interest attach to and follow mineral leases and future production "by operation of law," without any steps…