In Re the Appeals of CIG Field Services Co.

The opinion of the court was delivered by

Beier, J.:

CIG Field Services Company (CIG) appeals from a decision by the Board of Tax Appeals (BOTA), which upheld the Department of Revenue’s valuations and assessments for tax years 1997 to 2003. CIG contends that Kansas’ statutory differentiation between the tax treatment for interstate and intercounty gas gathering systems on the one hand and intracounty gas gathering systems on the other violates the federal Commerce Clause and the federal and state Equal Protection Clauses.

During the tax years in question, appellant CIG owned and operated…