Powder River Coal Co. v. Wyoming Department of Revenue

KITE, Justice.

[¶1] Powder River Coal Company (PRCC)produces coal and sells it away from the mouth of each of its mines. Wyo. Stat. Ann. § 89-14-108(b)(vii) (LexisNexis 2005) requires the coal be valued for severance and ad valorem tax purposes using the proportionate profits method. In applying this method, costs must be categorized as either direct or indirect and PRCC contended employee healthcare costs were indirect costs. The Department of Revenue (DOR) disagreed, determined those costs should be treated as direct mining costs, and assessed PRCC accordingly for production years 1997-2000.…