Green Construction Co. v. State, Department of Revenue

OPINION

RABINOWITZ, Justice.

This appeal challenges the Department of Revenue’s decision to assess additional taxes against the appellants under the Alaska Business License Act (ABLA) for the years 1972 through 1977.

I. FACTUAL AND PROCEDURAL BACKGROUND

Each taxpayer had entered into a contract with Alyeska Pipeline Service Company (“Alyeska”) to supply materials to and assist Alyeska in the construction of the Trans-Alaska Pipeline System.1 In accordance with their individual contracts, between 1972 and 1977 Alyeska paid the taxpayers a “total CONTRACT PRICE . .. consisting of the sum of…