Farmers Cooperative Ass'n v. State ex rel. Oklahoma Tax Commission

OPINION

HUNTER, Presiding Judge:

The Farmers Cooperative Association of Clinton, Oklahoma, (Clinton Coop or Appellant) is an agricultural cooperative association organized under the authority of the Cooperative Marketing Association Act, 2 O.S.1991 § 361 et seq. In 1992, Clinton Coop filed a claim for refund of franchise taxes paid for the three previous tax years, 1989-90 to 1991-92. Since that time, Clinton Coop has paid the assessed franchise taxes under protest. After the Business Tax Division of the Oklahoma Tax Commission denied the claim, Clinton Coop filed a protest of the denial. An…