Enron Oil & Gas Co. v. Freudenthal

Appellant, Enron Oil and Gas Company (Enron), applied for a severance tax refund with the Wyoming Department of Revenue and Taxation (Department) for the years 1987 through 1990. The Department granted the refunds for the years 1989 and 1990 but rejected Enron's claims for refunds for the years 1987 and 1988. Enron appealed the denial of its refund claims to the Board of Equalization of the State of Wyoming (Board) which concluded that the refund claims for 1987 and 1988 were barred by the two-year filing limit of W.S. 39-6-304(g) (1985) (Repealed by 1988 Wyo. Sess. Laws, ch. 90, § 2). The District Court affirmed the Board's decision, and Enron appealed to this court. We affirm.