Chevron U.S.A., Inc. v. State, Department of Revenue

OPINION

STOWERS, Chief Justice.

1. INTRODUCTION

In this appeal oil producers (the Producers) 1 challenge an administrative decision (the Decision) in which the Alaska Department of Revenue (DOR) decided to treat separate oil and gas fields operated by common working interest owners as a single entity when calculating the Producers’ oil production tax obligations. Relying on a statute that gave DOR the discretion to “aggregate two or more leases or properties (or portions of them), for purposes of determining [their effective tax rate], when economically interdependent oil or gas production…