Exxonmobil Corp. v. Utah State Tax Commission

WILKINS, Justice:

¶ 1 ExxonMobil Corporation (“ExxonMo-bil”) filed a petition for review of a Utah State Tax Commission (“Tax Commission”) decision upholding the denial of ExxonMo-bil’s request for a refund of allegedly miscalculated severance taxes on certain oil and gas interests. We reverse.

FACTUAL BACKGROUND

¶ 2 The essential facts of this case are not in dispute. ExxonMobil requested a refund of severance taxes it believes it overpaid from January 1, 1993 through December 31, 1998. During that period, ExxonMobil operated numerous oil and gas wells in southeastern Utah that were subject to…