BHP Petroleum Co., Inc. v. State

URBIGKIT, Justice.

A statutory construction issue, singularly important to Wyoming oil and gas producers and the Wyoming Department of Revenue and Taxation, is presented for consideration of the severance tax liability of the unit operator defined to be the “person extracting” for production from the Madden Deep Unit as a unitized field. 1 Appellant, BHP Petroleum Company, Inc. (unit operator), by a declaratory judgment complaint, challenged intended assessment on it of all severance tax within the unit. The judgment of the district court validated the unit operator tax assessment and we…