Standard Alaska Production Co. v. State, Department of Revenue

RABINOWITZ, Justice.

Standard Alaska Production Company (“Standard”) filed a complaint in superior court seeking a declaration that the Alaska Department of Revenue (“Department”) lacks authority to increase disputed tax assessments after three years have passed from the date the tax return was filed. The superior court dismissed the declaratory judgment action on the ground that Standard would first have to exhaust available administrative grievance procedures before seeking a judicial remedy. 1 This appeal followed.

I. FACTS AND PROCEEDINGS.

Standard timely filed its 1978 oil and gas corporate…