Amoco Production Co. v. Wyoming State Board of Equalization

GOLDEN, Justice.

Appellant (Amoco) seeks a refund of $3.5 million it claims it overpaid in oil and gas severance taxes from 1978 to 1984. On March 15, 1986, Amoco sent the Wyoming Department of Revenue and Taxation (Department) a letter stating that, based upon several reporting and accounting corrections, Amoco was lowering the value 1 of its gas production for 1978-1984. Based on the lower value, Amoco claimed it overpaid its severance tax during those years and asked the Department to refund the overpayments. 2

Acting on the attorney general’s advice, the Department told Amoco that only…