State v. Phillips Petroleum Co.

This is the second time this case has been before this Court. This case began when the *894State Department of Revenue assessed Phillips Petroleum Company, a natural gas producer, a privilege tax, along with penalties and interest. Phillips Petroleum paid the tax under protest and appealéd for a refund, arguing that the Revenue Department could not use the “work-back method” to figure the value of the gas for tax purposes. Initially, the trial court, after an ore tenus hearing, held that the Revenue Department could use the work-back method to calculate the value of the gas from the date the…