Amerada Hess Corp. v. State Ex Rel. Tax Commissioner

MARING, Justice.

[¶ 1] Amerada Hess Corporation (“Am-erada”), Tioga Gas Plant, Inc. (“Tioga”), Solar Gas, Inc. (“Solar”), and AH 1980 Program, Inc. (“AH”) appealed from a judgment affirming an order of the State Tax Commissioner assessing them more than $3,000,000 in additional back taxes, penalty and interest. We conclude the Commissioner did not err in his interpretation of the applicable tax statutes in assessing the additional taxes, penalty and interest. We affirm.

I

[¶ 2] Amerada and its wholly-owned subsidiaries, Tioga, Solar and AH, each conducted business in North Dakota during tax…