Shell Western E & P, Inc. v. Board of Supervisors of Pike County

DAN M. LEE, Presiding Justice,

for the Court:

This appeal brings a highly technical, complex factual situation as well as a difficult legal issue before the Court. The factual complexities involve the operation of a carbon dioxide (C02) enhanced oil recovery operation. The resolution of the legal question requires an interpretation of one statute in an intricate framework of taxation, exemption, and partial exemption.

Shell Western E & P, Incorporated (Shell), utilizes a variety of equipment in the capacity of operator of the Little Creek oil field. In essence, the equipment prepares C02 for…