Justia Tax Law Opinion Summaries

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

The case involves a divorce between Guy Morrison, III (Husband) and Tami Hinson-Morrison (Wife), who married in 2007. Before the marriage, they signed a premarital agreement stating that each party would retain their individual property, any property acquired from the proceeds or appreciation of their premarital property, and any property acquired by gift or inheritance. During the marriage, Husband formed three oil and gas companies and made various financial contributions to Wife's businesses and properties. Wife filed for divorce in 2022, leading to disputes over the interpretation and application of the premarital agreement and the equitable distribution of assets and debts.The District Court of Campbell County found the premarital agreement clear and unambiguous, except for its silence on commingling of funds. The court ruled that Husband's financial contributions to Wife's properties were spousal gifts and did not warrant compensation. The court divided the remaining marital assets and debts equitably, awarding Husband his businesses and other assets, while Wife retained her businesses and the marital home. The court also ordered the parties to file joint tax returns for 2021 and 2022 and bear their respective tax obligations proportionally.The Supreme Court of Wyoming affirmed the district court's decision. It held that the premarital agreement was clear and enforceable, and the district court correctly interpreted it without adding a commingling provision. The court also found no abuse of discretion in the equitable distribution of assets and debts, noting that the division left both parties in a comfortable financial position. The court declined to award Wife attorney fees, as the fee-shifting provision in the premarital agreement did not apply to the divorce proceedings. View "Morrison v. Hinson-Morrison" on Justia Law

In 2014, a woman and her two children from a previous relationship moved in with a man. They had a child together in 2018 and married in 2019. The man ran a trucking business, and the woman assisted with bookkeeping. She also worked briefly at a mental health facility and later as a secretary at a hospital. The couple separated in March 2022, and the woman filed for divorce shortly thereafter.The District Court of Weston County entered a stipulated decree of divorce in January 2023, settling child custody, visitation, and child support. However, the division of marital property was disputed. A bench trial was held in April, and the court issued its final order in November, dividing the marital property. The court considered the equitable value of the marital home, rental property, livestock, personal vehicles, personal property, and debts. The man was assigned the marital home, while the woman received her retirement funds and an equalization payment from the man.The man appealed to the Supreme Court of Wyoming, arguing that the district court abused its discretion in dividing the marital property. He contended that the court failed to allocate a portion of an IRS debt to the woman and improperly valued his trucking business. The Supreme Court reviewed the district court’s findings for an abuse of discretion and found no clear error. The court noted that the district court had appropriately considered the statutory factors under Wyo. Stat. Ann. § 20-2-114(a) and had made a just and equitable division of the property.The Supreme Court of Wyoming affirmed the district court’s decision, concluding that the property division was not so unfair and inequitable that reasonable people could not abide by it. The court also found that the district court had reasonably considered each of the statutory factors and that its ruling did not shock the conscience. View "Regan v. Regan" on Justia Law

This case involves a dispute over the tax assessments of 115 vacant lots in the Sunup Ridge subdivision in Converse County, Wyoming, owned by Jan Gray. Gray appealed the Converse County Board of Equalization’s decisions upholding the Converse County Assessor’s tax assessments for the years 2016, 2017, 2018, and 2020. He contended that the County Assessor failed to physically inspect each lot as required by law, and that the tax assessments were not supported by substantial evidence. Additionally, he argued that the County Board did not provide an adequate record on appeal and that he was denied an opportunity for proper discovery.The Supreme Court of Wyoming upheld the County Board's decisions. The court found that the County Assessor had complied with the requirement to physically inspect the properties, and that the tax assessments were supported by substantial evidence. Furthermore, the court determined that the County Board had provided an adequate record for appeal and that Gray had not been denied an opportunity for discovery. Therefore, the court affirmed the County Board's tax assessments for the years in question. View "Jan Charles Gray v. Converse County Assessor" on Justia Law

The Supreme Court affirmed the decision of the Board of Equalization affirming the Wyoming Departments of Audit and Revenue's mineral tax audit assessments of Chesapeake Operating, LLC's oil and gas production, holding that the State Board of Equalization did not misinterpret Wyo. Stat. Ann. 39-14-203(b)(iv) when it found that Chesapeake's field facilities did not qualify as processing facilities.On appeal, Chesapeake argued that the Board erred in concluding that Chesapeake's facilities qualified as processing facilities under the mineral tax statutes and that the proper point of valuation for its gas production was at the custody transfer meters. The district court certified the case directly to the Supreme Court, which affirmed, holding that the Board correctly interpreted and applied Wyo. Stat. Ann. 39-14-201(a)(xviii) when it found that the seven facilities at issue were not processing facilities. View "Chesapeake Operating, LLC v. State, Dep't of Revenue" on Justia Law

The Supreme Court affirmed the decision of the Board of Equalization upholding the final determinations of the Department of Revenue (DOR) increasing the taxable value of Jonah Energy LLC's natural gas liquids (NGL) production for 2014 through 2016, holding that Jonah was not entitled to relief on its allegations of error.On appeal, Jonah argued that the Board misinterpreted the NGL purchase agreement between Jonah and the purchaser of its NGL, Enterprise Products Operating LLC, by refusing to account for deficiency fees Jonah paid to Enterprise in determining the NGL's taxable value. The Supreme Court affirmed, holding (1) the Board did not misinterpret the NGL purchase agreement at issue; and (2) the Board did not err by failing to take the facts and circumstances surrounding execution of the purchase agreement into account when interpreting it because there was no basis for losing outside the four corners of the purchase agreement to determine its meaning. View "Jonah Energy LLC v. Wyo. Dep't of Revenue" on Justia Law

The Supreme Court reversed the decision of the district court holding that three roadside services offered by Big Al's Towing and Recovery were taxable under Wyo. Stat. Ann. 37-15-103(a)(i)(J), holding that the Wyoming Board of Equalization correctly concluded that the roadside services were not taxable under the statute.At issue were Big Al's roadside services for jumping-starting a vehicle, unlocking a vehicle, and replacing a flat tire with a spare tire. The Wyoming Department of Revenue determined that Big Al's owed taxes and interest on the roadside assistance revenue it collected between 2016 to 2019. The Board reversed, concluding that the roadside services did not constitute a taxable event. The district court reversed, ruling that the services were taxable under section 39-15-103(a)(I)(J). The Supreme Court reversed, holding that the Board's decision that Big Al's roadside services were not taxable under the statute was in accordance with law. View "Big Al's Towing & Recovery v. State, Department of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Wyoming State Board of Equalization (Board) affirming the tax assessment set forth by the Wyoming Department of Revenue (DOR) imposing severance and ad valorem property taxes on the waste mine gas (WMG) captured and used by Solvay Chemicals, Inc., holding that there was no error.Solvay used the WMG released from its trona mining operations to help fuel its soda ash processing plant during the years 2012 through 2015. The DOR imposed severance and ad valorem taxes on the WMG during those years. Solvay objected, arguing that the WMG was not taxable under the severance or ad valorem tax statutes. The Supreme Court affirmed, holding that Solvay failed to show the DOA and DOR improperly valued the WMG for production years 2012-2015. View "Solvay Chemicals, Inc. v. Wyoming Dep't of Revenue" on Justia Law

The Supreme Court affirmed the ruling of the State Board of Equalization affirming the decision of the Wyoming Department of Revenue disallowing a deduction of bagging costs from the taxable value of its bagged soda ash, holding that Solvay Chemicals, Inc. was not entitled to deduct bagging costs from the taxable value of soda ash.In 2013-2015, Solvay deducted its soda ash bagging costs from the taxable value of the bagged soda ash it sold. The Department determined that Wyo. Stat. Ann. 39-14-303(b) did not entitle Solvay to a separate deduction for bagging costs, and the Board and district court affirmed. The Supreme Court affirmed, holding that the Board did not err in determining that the Department's interpretation of section 39-14-303(b)(ii) was not erroneous or contrary to the plain language of Wyo. Stat. Ann. 39-14-303(b)(iv). View "Solvay Chemicals, Inc. v. Wyoming Department of Revenue" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the Wyoming Board of Equalization (Board) concluding that WPX Energy Rocky Mountain, LLC was entitled to deduct some of its "reservation fees," holding that the Board erred in interpreting the plain language of Wyo. Stat. Ann. 39-14-203(b)(vi)(C) in its decision.At issue on appeal was whether and to what extent WPX was entitled to deduct "reservation fees" under the "netback" severance tax valuation method, section(vi)(C), for natural gas production years 2013-2015. The Board concluded that WPX was entitled to deduct some of its reservation fees. The Supreme Court reversed in part, holding (1) the statute allows WPX to fully deduct its pipeline reservation fees for months when some but not the full reserve capacity of gas was transported on that pipeline; (2) the statute does not allow WPX to deduct its Bison Pipeline reservation fees for months when it shipped no gas on the pipeline; and (3) the Board's conclusion that WPX cannot deduct any portion of its Bison Pipeline reservation fees it used to recoup pipeline construction costs was contrary to the plain language of the statute and the Bison agreement. View "Wyo. Department of Revenue v. WPX Energy Rocky Mountain, LLC" on Justia Law