TGS-NOPEC GEOPHYSICAL CO. v. Combs

OPINION

JAN P. PATTERSON, Justice.

This appeal arises from a franchise tax dispute involving the apportionment of gross receipts from the licensing of geophysical and seismic data. The parties filed cross-motions for summary judgment, and the trial court granted summary judgment in favor of the Comptroller 1 on the issue of tax liability but, finding that the Comptroller abused her discretion in denying appellant TGS-NOPEC Geophysical Company’s requests to waive penalties and interest, the trial court granted summary judgment to TGS on that issue. TGS appeals the trial court’s summary judgment…