Williams v. BP Alaska Exploration, Inc.

*237OPINION

RABINO WITZ, Justice.

This appeal involves disputed assessments by the Department of Revenue (Department) under the Alaska Business License Act (ABLA)1 for taxpayers’ activities in the years 1972 through 1975.2

The major controversy in this litigation is whether the Department properly concluded that 695 million dollars were “gross receipts” for ABLA purposes. This money was received by the taxpayers under a series of “operating agreements” where one or the other of the taxpayers acted as the “operator” of certain oil, gas, and mineral leases within Alaska. The responsibilities of the…