Bullock v. Sage Energy Co.

SHANNON, Chief Justice.

Sage Energy Company filed suit in the district court of Travis County for refund of $328,667.50 in franchise taxes paid to the Comptroller of Public Accounts. In its suit Sage attacked a rule of the Comptroller relating to the preparation and contents of the franchise tax report. Sage asserted that the rule, as construed and applied by the Comptroller, requires the assessment of its franchise tax on the basis of capitalized intangible drilling and development costs while other similarly situated taxpayers are allowed to expense such costs. Sage claimed that such…