State v. Phillips Petroleum Co.

We granted the State of Alabama's petition for certiorari review to examine, as an issue of first impression in this State, whether the Department of Revenue could use the "work-back" method to calculate the value of natural gas at the wellhead in order to assess the privilege tax under §40-20-2(a), Ala. Code 1975. The State also raises an issue of whether any refund of such privilege taxes, paid under protest, portions of which were passed on to the counties and municipalities, is payable by the State without contribution from the counties and/or municipalities that received a portion of the…