Belnorth Petroleum Corp. v. State Tax Commission

OPINION

BENCH, Judge:

Petitioner, Belnorth Petroleum Corporation (Enron Oil & Gas Co.) (hereafter “Enron”) seeks review of a ruling by the State Tax Commission. The Commission held that Enron paid insufficient occupation and conservation taxes on the natural gas it produced between 1980 and 1984. We reverse.

BACKGROUND

Enron is one of the largest producers of natural gas in Utah. From 1980 to 1984, Enron sold natural gas pursuant to several contracts that required the purchasers to reimburse Enron (in whole or in part) for ad valorem taxes paid by Enron to the State. In addition to paying ad…