BEFORE THE STATE BOARD OF EQUALIZATION
FOR THE STATE OF WYOMING
IN THE MATTER OF THE APPEAL OF )
CAMPBELL COUNTY ASSESSOR AND THE )
BOARD OF COMMISSIONERS OF CAMPBELL ) Docket No. 96-90
COUNTY FROM A MINERAL TAX DECISION )
BY THE DEPARTMENT OF REVENUE )
FINDINGS OF FACT
CONCLUSIONS OF LAW
DECISION AND ORDER
Jerry Shatzer, Campbell County Assessor and the Board of Commissioners of
Campbell County, by Carol Seeger, at the time of filing briefs and James Schermetzler at
the time of the hearing, Deputy Campbell County Attorneys.
Mike Basom at the time for filing briefs and Karl D. Anderson at the time of the
hearing, Assistant Attorney Generals for Respondent, Department of Revenue.
Richard E. Day and Margo Harlan Sabec, attorneys for Intervenor Devon Energy Production
The appeal arises from Notice of Appeal dated July 19, 1996, appealing the
certification of taxable value from the production of minerals occurring in the North Buck
Draw Unit from the Department of Revenue (DOR) dated June 20, 1996. This matter was
considered by the State Board of Equalization (SBOE) consisting of Roberta A. Coates and
Ron Arnold. Edmund J. Schmidt, Board Chairman, recused himself from consideration and
participation in this matter. The SBOE considered briefs, pleadings and exhibits pursuant
to a Briefing Order dated August 18, 1997. The Board having found that material facts were
in dispute and desiring to receive evidence and oral arguments converted the matter to a
hearing pursuant to an Order dated August 11, 1999.
Taxpayer had injected outside substance gas (OSG) in the formation to enhance oil
recovery. After "blowdown" the Taxpayer produced gas that may include reservoir
gas and the OSG. The DOR and the Taxpayer argued that tax on produced gas should not be
paid until the same volume of gas as had been injected as OSG, adjusted for heating value,
ALL STATUTORY CITATIONS USED IN THIS DECISION AND ORDER REFERENCE TITLE 39,
PRIOR TO RECODIFICATION WHICH WAS EFFECTIVE MARCH 6, 1998.
Upon application of any person adversely affected, the SBOE is mandated to
review final decisions of DOR on excise taxes and "[h]old hearings after due notice
in the manner and form provided in the Wyoming Administrative Procedure Act (Wyo. Stat
16-3-101 through 16-3-115) and its own rules and regulations of practice and
procedures." Wyo. Stat 39-1-304(a)(ix).
The Board is required to "[d]ecide all questions that may arise with reference to
the construction of any statute affecting the assessment, levy and collection of taxes, in
accordance with the rules, regulations, orders and instructions prescribed by the
department." Wyo. Stat 39-1-304(a)(iv). The rules of practice and procedure
for appeals before the Board involving tax matters contemplate appeals from final
administrative decisions of DOR. Rules, Wyoming State Board of Equalization, Chapter
2, Section 3. The rules require appeals to be filed with the Board within thirty (30)
days of any administrative decision. Rules, Wyoming State Board of Equalization,
Chapter 2, 5.
Devon Energy Production Company is the successor in interest to Kerr-McGee
Corporation (jointly referred to as Taxpayer). Kerr-McGee developed an oil field by
purchasing gas from another field and injecting that gas to create pressure to produce
oil. The injected gas had been severed prior to the reinjection and all taxes had been
paid prior to the reinjection. The DOR determined the reinjected gas should not be taxed
when it is produced from the North Buck Draw Unit, NBDU. In an attempt to forgo taxes for
the outside substance gas (OSG) the DOR allowed the Taxpayer to not pay taxes on the same
volume of injected OSG, adjusted for heating value. When DOR certified no value for the
gas first produced the Campbell County Assessor and the Campbell County Commissioners
(jointly referred to as Petitioners) appealed.
The issue originally argued by Petitioners was whether produced gas, even if it was
injected gas, is exempt from taxation.
The DOR and subsequently the Taxpayer countered this argument by asserting that Wyo.
Stat. 39-14-201(a)(xiii), enacted after the appeal was filed, defines natural gas to
exclude injected gas and therefore the injected gas is not taxable.
At the time of the hearing, the Petitioners argued that the injected gas should be
valued for tax purposes at the price received for the produced gas, less the price for the
The DOR and the Taxpayer attempted to demonstrate the Petitioners' method of valuing
injected gas was difficult to administer and if the price of gas fell from the time of
injection to the time of production, a volume of produced gas would not be taxed.
FINDINGS OF FACT
1. The SBOE received a Notice of Appeal by the Petitioners from a
Determination and Certification of Department of Revenue dated July 18, 1996.
2. North Buck Draw Unit (NBDU) oil and gas field is located in Campbell County,
Wyoming. The Unit is a high-pressure miscible gas injection project. In a miscible gas
project a substance, in this case hydrocarbon gas, is injected into the reservoir to
maintain minimum miscibility pressure so that the crude oil does not flash to a gas phase.
The miscibility improves the recovery of the crude oil from the reservoir by maintaining
pressure. [Transcript p. 224]. The projections are that the injection
process actually produced 14 million barrels of oil more than if the reservoir had simply
been depleted. [Transcript p.128, 129]. It is estimated that 65% of the
oil in the reservoir will be produced and it is estimated by Taxpayers expert petroleum
engineer, George J. Fulco, that only 25% would have been produced if the injection method
had not been used. [Transcript p.147, 148]. The information presented to
the Wyoming Oil and Gas Commission estimated that if enhanced recovery did not occur only
$92 million would be produced and with enhanced recovery miscible gas injection project
the value of the products increased to $271 million. [Transcript p. 219].
3. The first miscible flood project in the State similar to the NBDU project occurred
in the Powell Pressure Maintenance Unit in approximately 1985. [Transcript p.
4. The reserves in the NBDU were estimated by the Wyoming Oil and Gas Commission to be
36 million barrels of oil and 7.6 bcf of gas. [Transcript p. 216].
5. The gas injected in the North Buck Draw Unit was produced from another field and is
referred to as outside substance gas, (OSG). The gas was purchased from an interstate
pipeline company and the Taxpayer does not know where the gas was produced or the wellhead
price or value of the OSG at the time of production. [Transcript p.137, 231].
The former Director of the Wyoming Oil and Gas Commission, Donald Basko, testified that he
believed the OSG came from the Hilight Plant and the Kitty Plant which are both located in
Campbell County, Wyoming. [Transcript p. 243].
6. The OSG gas was probably a hydrocarbon that was naturally occurring beneath the
earth's surface when it was produced. [Transcript p. 272]. The OSG does
not naturally occur in the NBDU.
7. In March, 1995, it was determined that the injection of outside gas in the reservoir
was no longer necessary to maintain pressure because the reinjection of the field gas and
water would result in enough pressure to maintain the unit. Therefore, the Taxpayer
started selling the gas from the reservoir. This was the same process used on the Powell
Pressure Maintenance Unit. [Transcript p.130, 131]. The method of not
taxing the first gas produced is one of the accepted practices of the Council of Petroleum
Accounting Society, COPAS. [Transcript p. 368]. It is the same method
that this SBOE mandated in the Powell Pressure Maintenance case, Kerr-McGee
Corporation, Docket 94-29, (December, 1994).
8. From September 1988 through February 1995, when OSG purchases ceased, a total of
20,598,980 MMBTU of OSG (18.1 BCF) was purchased off lease and injected into the NBDU. The
average price paid for the OSG during this period of time was $1.89/MMBTU, for a total of
$39,018,229.42, and of that amount $5,010,526.64 was the cost of transportation. [Stipulation,
filed March 31, 2000, paragraph 6, Transcript p. 70, 137].
9. In 1995 the operator started injecting water into the unit and selling gas and from March 1995, to August 1999, 5,330,089 MMBTU (4.1 BCF) of gas has been produced and sold from NBDU. "Blowdown" occurred in August 1999 to December 1999, and an additional 5,442,004 MMBTU's (4,490,742 MCF) of gas was produced. As of December 31, 1999, 7,378,283 MMBTU of gas was sold from NBDU and no severance or ad valorem tax was collected. [Stipulation, filed March 31, 2000].
10. By Order dated March 18, 1988, the Wyoming Oil and Gas Conservation Commission
(WOGCC) approved the Unit Agreement and the Unit Operating Agreement for the development
and operation of the NBDU and certified the proposed operation as a qualified tertiary
recovery project exempt from Wyoming excise tax under Wyo. Stat. 39-6-302(j). Kerr-McGee
was a working interest owner and the Unit Operator at the time of the order. Subsequently,
Devon acquired all Kerr-McGee's interest in the NBDU and is presently the Operator of the
Unit. [Transcript p. 135].
11. The sales value, market value and taxable value of the OSG is not the same as the
market value, sales value and taxable value of the gas being produced and sold from the
unit. [Transcript, p. 67].
12. The gas injected was different from the gas produced because the heating value or
Btu of the produced gas was higher. It is impossible to distinguish between what is
injected gas and the produced reservoir gas. [Transcript p.154, 155]. The
produced gas was probably composed of OSG and reservoir liquids or reservoir gas. [Transcript
p. 248, 251, 252]. The injected gas comprises approximately 92 percent of the
produced gas. [Transcript p. 250].
13. The parties stipulated that the ad valorem taxes and severance taxes had been paid
on the OSG prior to its injection into the North Buck Draw Unit. [Stipulation
paragraph 10, Transcript p.278].
14. The parties stipulated the average Btu content of the OSG is 1.14.
[Stipulation para. 18]. Taxpayer accounted for the value of the OSG in its books
to be $1.89 per MMBTU. [Transcript p.67, Petitioners Exhibit 128].
Included in the cost to purchase the gas for injection were transportation charges that
ranged from 20 cents to 28 cents per MMBTU. [Transcript p.69].
15. The average Btu content of the gas sold from the NBDU during the period of March
1995, through November 1999, is 1.25 [Transcript p. 66].
16. On June 2, 1995, Kerr-McGee Corporation requested the DOR exempt from severance and
ad valorem tax 18.1 BCF (billion cubic feet) of outside substance gas that was produced
from an outside unit and reinjected into the North Buck Draw Unit to stimulate oil
production. The request was to exempt from tax the same volume of gas, adjusted for
heating value, when that volume was produced from the Unit. [Transcript p.
140-141, 296, DOR Exhibit 500 and 502]. This method of accounting for the OSG gas
is generally accepted in the industry. [Transcript p. 145].
17. The heating value of the injected gas was 20.6 million MMBTU. Btu is the heating
measure of natural gas and determines the value of the gas to the consumer. It is
estimated, if the same amount of Btu is produced and sold from the unit as was injected
into the unit, and computing the heating value change of the produced gas from the
injected gas only 16.7 BCF would be exempt instead of 18.1 BCF. [Transcript p.
18. Gas is primarily valued by its heating value or Btu content. [Transcript p.
139, 233, 234]. Market factors other than Btu do influence the price paid for the
gas. [Transcript p. 263].
19. On March 11, 1996, DOR issued a revenue ruling agreeing to the following:
1. From the commencement of the North Buck Draw Unit "Modified Plan of
Development" in March of 1995, all gas will be deemed as severance and ad valorem tax
free until such time as the entire 18.1 BCF (adjusted for heating value) inventory of
outside substance gas is produced, at which time the owners will resume payment of
severance and ad valorem taxes on all gas produced from the unit. At all times taxes will
be paid on the natural gas liquids resulting from processing the gas.
2. The Department requires that Kerr-McGee, as Operator of North Buck Draw Unit, provide the mineral tax division with a report detailing the amount of "outside substance gas" purchased, from whom it was purchased, the amount that has been produced to date, when "blow down" will occur, and any forecast of approximately when the 18.1 BCF of gas will ultimately be recovered. We also require the operator of the North Buck Draw Unit to provide the mineral tax division with an annual report, no later than December 31st of each year, setting forth the cumulative total of "outside substance gas".
[Petitioners' Exhibit 108, DOR Exhibit 502 and Transcript p.141-142, 297].
20. Taxpayer agreed to pay taxes on the natural gas liquids resulting from processing
the gas. [DOR Exhibit 502 and Transcript 142].
21. The royalty interest owners agreed to the accounting method used by the DOR and the
Wyoming State Land Office agreed to the accounting method used by the DOR in calculating
royalties. [Transcript, p. 83, 84]. The accounting method used by DOR is
common practice in the industry based on the Wyoming Oil and Gas Commission treatment on
three wells in Wyoming, the Colorado Oil and Gas Commission treatment of one well in
Colorado, and the California Oil and Gas Commission treatment of two wells. [Transcript,
p. 238, 245].
22. Taxpayer purchased the OSG and the Unit Agreement provided that a like amount of
the OSG would be royalty free until the total volume equaled the total volume of OSG. The
agreement also provided that the working interest owners own the OSG and not the royalty
holders. [Transcript p.133, 134].
23. Between 1988 and 1995, 18.1 billion cubic feet of outside substance gas, OSG, was
not reported for tax purposes. Beginning in March of 1995, and continuing to November
1999, unit sales of gas from North Buck Draw were not reported for ad valorem tax
purposes. [Transcript p. 64].
24. The Department has not adopted any rules concerning the valuation of injected
outside source gas. [Transcript p. 372].
25. The Petitioners introduced and their expert witness, Mr. Fetterolf, testified about
an exhibit prepared to estimate how much tax dollars may be forgiven if the value of
produced gas is not taxed in proportion to the value of injected gas. He also attempted to
explain how DOR might calculate the total tax value of the injected gas. [Petitioners
Exhibit 128]. The conclusion of Petitioners' analysis is that utilizing all of
the expert's assumptions and using the average price for gas in Campbell County, $20
million dollars of value is escaping taxation. The total tax value shown on the exhibit
did not allow a deduction for allowable deductions such as exempt royalties or processing
costs. Also the value assigned to the purchased gas is an estimate because the value of
the gas at the well-head is not available. The exhibit estimates of value are based on
sales price in November, 2000. The exhibit included no adjustment for the time/value of
money.[Petitioners Exhibit 129, Transcript p.81, 85-95, 101-102, 104-105].
26. If the price of gas were to decrease from the time of injection to the time of
production, and the gas were taxed on the value basis as proposed by Petitioners then it
would be possible for a volume of reservoir gas to be produced tax free. [Transcript
27. Taxpayer owns a 42% working interest in the NBDU and the other working interest
owners are not selling their gas under the same marketing agreement as Taxpayer. Taxpayer
does not know what the marketing arrangements are for the other working interest owners so
that it would be difficult to value the gas as it is sold. [Transcript p.150].
28. The DOR representative, Mr. Randy Bolles, explained that another difficulty in
using the method propounded by the Petitioners is that the value of natural gas is
established by an arm's length sale as close to the production as possible. The DOR does
know the value of the OSG gas when first sold after production. Subsequent sales of gas
after the first sale is not examined by the DOR. Therefore, the subsequent sale to
entities such as the Taxpayer is not a true measure of value. [Transcript
p.279-282]. It would be difficult to value the OSG because it is a combination of
gas, from numerous wells, that may have different taxable values. [Transcript p.
29. Another method to avoid taxing the OSG and taxing only the reservoir gas is to
determine the proportion the OSG bears to the entire amount of gas produced from the
reservoir. This could be done by comparing the percentage of the Btu content of the OSG
gas to the Btu content of the produced gas and then taxing only that percent of the Btu
increase of the produced gas. In this case it can be computed that the OSG Btu percent
contributed at least 92% of the Btu content of the produced gas and therefore only 8% of
the produced gas should be taxed. [Transcript, p. 249 - 255, 257-258].
This method presupposes that the Btu content of the produced gas will remain constant and
this may not, in fact, happen. [Transcript, p. 267].
30. Methods for valuing outside substance injected gas are contained in Bulletin No. 7,
Revised 1997, by the Council of Petroleum Accountants Societies. The suggested methods
[Exhibit IV to Petitioners' Response to Questions Posed by Board of
Equalization Following Closing Arguments, Exhibit B, Department's Response to Board's
31. On June 20, 1996, the DOR sent a letter to the Campbell County Assessor detailing
the valuation of natural gas for the 1996 tax year which included the valuation of gas for
Kerr-McGee, North Buck Draw Unit. The letter contained a Schedule C which showed that an
estimated total of $5,156,643 value of gas would not be taxed. [Petitioners'
32. The County filed a Notice of Appeal with the SBOE on July 19, 1996, from the DOR
letter. [SBOE Record].
33. Subsequent to the Notice of Appeal the DOR again met with the Taxpayer. The County
was not represented at the meeting. The Taxpayer and the DOR again agreed that the
Taxpayer would account for the volume of the produced gas as it left the unit and the
Taxpayer did not have to account for different sales agreements. The agreement reached at
this meeting was reduced to writing by a letter from DOR to Taxpayer dated June 18th,
1999. [Transcript p. 143, 144, 310 DOR Exhibit 509]. The letter refers to
exempting gas produced based on a mcf basis but it was meant to be a Btu basis.
[Transcript p. 311, 312].
34. Any Conclusion of Law below which includes a Finding of Fact may also be considered
a Finding of Fact and is therefore incorporated herein by this reference.
CONCLUSIONS OF LAW
35. Petitioners' letter of appeal was timely filed and the SBOE has
jurisdiction to determine this matter.
36. The applicable statutes which are determinative in this matter provide in relevant
Wyo. Stat. 39-6-302
(j) Tertiary production resulting from projects certified by the Wyoming oil and gas
conservation commission after July 1, 1985, and before March 31, 2001, is exempt from the
severance taxes imposed by W.S. 39-14-204(a)(iii) for a period of five(5) years from date
of first tertiary production. A taxpayer claiming a tax reduction under this subsection is
prohibited from claiming a tax reduction provided by subsection (f) and (g) of this
(k) In the case of tertiary production of crude oil resulting from injection of carbon
dioxide gas all Wyoming severance taxes paid on the carbon dioxide gas injected shall be
deducted from and allowed as a credit against the severance taxes imposed on the oil
produced by the injection.
Wyo. Stat. 39-2-208
(f) Natural gas which is vented or flared under the authority of the Wyoming oil and
gas conservation commission and natural gas which is reinjected or consumed prior to sale
for purpose of maintaining, stimulating, treating, transporting or producing crude oil or
natural gas on the same lease or unit from which it was produced has no value and is
exempt from taxation.
Wyo. Stat. 39-1-201(a)
The department shall annually value and assess the following property at its fair
market value for taxation:
(i) The gross product of all mines and mining claims;
Wyo. Stat. 39-1-303(a)
In addition to the other powers and duties imposed by law, the department shall:
(ii) Insure specialized service for tax enforcements, through establishment and
maintenance of uniformity in definition, regulation, return and payment;
(xxxii) Promulgate rules and regulations consistent with the provisions hereof as
provided by the Wyoming Administrative Procedure Act, necessary to the enforcement of the
provisions of any or all tax and other revenue measures which are administered by the
37. The Petitioners have the burden of going forward and the ultimate burden of
persuasion. [see, Rules, Wyoming State Board of Equalization, Chapter 2, 19]. Is
the Outside Substance Gas Taxable When It Is Produced From the Injected Formation?
38. If the gas were injected from the same field then it would be exempt from taxation.
Wyo. Stat. 39-2-208(f) and DOR Rule, Chapter 6, Section 8(e). However, the injected
gas is not from the same formation therefore neither Wyo. Stat. 39-2-208(a) nor
the other exemptions contained in Wyo. Stat. 39-6-302 are applicable.
39. The definition of natural gas contained in Wyo. Stat. 39-14-201(a)(xv),
effective March 6, 1998, states:
"Natural gas" means all gases, both hydrocarbon and nonhydrocarbon, that occur naturally beneath the earth's crust and are produced from an oil or gas well. For the purposes of taxation, the term natural gas includes products separated for sale or distribution during processing of the natural gas stream including, but limited to plant condensate, natural gas liquids and sulfur.
This definition was not in effect at the time the Certification of Value was sent to
the County or at the time the Notice of Appeal was filed to this SBOE, July 19, 1996.
Moreover, when the Title 39 recodification was completed, the legislature announced there
was no intent to change the law, particularly the definitions, however, this definition is
new to the tax code. We will not retroactively apply the new definition. Chapman v.
Meyers, 899 P.2d 48 (Wyo. 1995).
We also cannot interpret Wyo. Stat. 39-14-201(a)(xv) to exclude the outside substance
gas from the definition of "natural gas." At the time of original production,
the outside substance gas was a hydrocarbon gas that occurred naturally beneath the
earth's crust and was produced from an oil and gas well. The DOR and Taxpayer argue the
definition demands that the gas be naturally beneath the earth's crust when it is produced
from the North Buck Draw Unit. We cannot insert the words "in the unit" in this
definition. The language in the definition is clear and it would violate statutory
construction rules to insert another qualifier. Wyo. Stat. 8-1-103.
We do, however, note the similarities to the definition used by the Wyoming Supreme
Court when it defined "natural gas" for purposes of the revenue and taxation
statutes in Amoco Production Co. v. State, 751 P.2d, 379 at 382-283, (Wyo. 1988).
The Court stated:
The great weight of authority compels us to the conclusion that the legislature used the word natural gas in it technical sense, and that the most sensible and appropriate resolution of this question is that the legislature intended natural gas to include all gases that occur naturally in gas produced from drilled wells.
40. We do believe that the outside substance gas is not taxable because, as was
stipulated by the parties, the taxes have been paid prior to production from the North
Buck Draw Unit and to tax the same gas would result in double taxation. Ad valorem tax
imposed on minerals is a property tax which taxes the full value of the mineral produced. Wyoming
State Tax Commission v. BHP Petroleum Company Inc., 856 P.2d 428, 434 (Wyo. 1993). It
is unlike the annual real property tax because it is imposed once, on production. Double
taxation would occur if the gas were produced twice and subjected to the same kind of tax.
Is the Method, to Exempt from Taxation the Outside Substance Gas
as Employed by DOR and Agreed to by Taxpayer Arbitrary and Capricious?
41. DOR and Taxpayer agreed to deduct from taxation the same volume of gas, adjusted
for heating value, that was injected from another formation before assessing severance or
ad valorem taxes. This is the same method agreed to in the operating unit agreement,
accepted by the Wyoming State Land Office, accepted by the Wyoming Oil and Gas Commission
and is a generally accepted method in the oil & gas industry.
42. This method is reasonable because it considers the primary factors that determine
the value of the product, volume and heating value.
43. This method is acceptable to the Council of Petroleum Accountants Societies.
44. The method advanced by the Petitioners, deducting the value of the injected gas
from the value of the produced gas, would be difficult to administer because of the
problem of valuing the injected gas. Many assumptions must be made to make the
calculation. Finally, this method may result in a volume of gas not being taxed if the
price of gas decreases from the time the injected gas is first produced to the time the
gas is produced for the second time. We can find no support for this method by the Council
of Petroleum Accountants Societies.
45. The Council of Petroleum Accountants Societies have announced other methods for
exempting outside substance gas. The other two methods have validity. One method is to:
This is the method DOR attempted to use in the Kerr-McGee Corporation, Docket
94-29, (Dec. 1993) case. The prior SBOE rejected that method. We believe that the SBOE
erroneously relied on a ruling of the Wyoming Oil and Gas Commission to reach that
conclusion. Months after the SBOE decision the Wyoming Supreme Court held that tax
decisions could not be made by the Wyoming Oil and Gas Commission. Kerr-McGee v. Wyo.
Oil & Gas Conservation Commission, 903 P.2d 537, 538 (Wyo. 1995). If the DOR were
to determine it was appropriate to exempt injected gas production based on a proportion it
may be upheld.
Another method the Council of Petroleum Accountants Societies has provided is:
An advantage of this method is that it would encourage full production of gas and
dissuade premature shutting in of units.
46. This SBOE cannot usurp the authority of DOR to determine the method most
appropriate to exempt outside substance gas from taxation. Amoco Production Company v.
Wyoming State Board of Equalization, 2000 WL 359196 (Wyo. April 10, 2000).
47. The program of injecting outside substance gas to encourage oil production is not
new in this state. It was used in 1985 on the Powell Pressure Maintenance Unit. The DOR
has not adopted any rules to exempt the outside substance gas and this is disturbing.
There have been many years to adopt such a rule. Two cases have been litigated before this
SBOE on this question. It is apparent the Taxpayer was concerned, a concern which need not
occur if a rule had been adopted. An advantage of such a rule is that future Taxpayers
would have notice of the method that would be used resulting in uniformity of taxation.
Uniformity may not result if the DOR continues to make individual agreements with
Taxpayers. Another rationale for a rule is that all parties would have an opportunity to
present their ideas. The Petitioners in this case were only able to comment in an appeal.
48. We conclude the DOR appropriately exempted from taxes the outside substance gas by
an appropriate method.
THIS SPACE INTENTIONALLY LEFT BLANK
IT IS THEREFORE ORDERED certification of value is affirmed.
Pursuant to Wyo. Stat. 16-3-114 and Rule 12, Wyoming Rules of Appellate
Procedure, any person aggrieved or adversely affected in fact by this decision may seek
judicial review in the appropriate district court by filing a petition for review within
30 days of the date of this decision.
Dated this 23rd day of May, 2000.
STATE BOARD OF EQUALIZATION
Roberta A. Coates
Ron Arnold, Member
Kathleen A. "Cindy" Lewis" Executive Secretary