EQT Production Co. v. County of Wise

CourtSupreme Court of Virginia
DecidedMay 21, 2026
Docket250430
StatusPublished

This text of EQT Production Co. v. County of Wise (EQT Production Co. v. County of Wise) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EQT Production Co. v. County of Wise, (Va. 2026).

Opinion

PRESENT: Powell, C.J., Kelsey, McCullough, Russell, and Mann JJ., and Millette and Mims, S.JJ.

EQT PRODUCTION COMPANY, ET AL. OPINION BY v. Record No. 250430 CHIEF JUSTICE CLEO E. POWELL MAY 21, 2026 COUNTY OF WISE, VIRGINIA, ET AL.

FROM THE COURT OF APPEALS OF VIRGINIA

EQT Production Company; EQT Gathering, LLC; and Diversified Production, LLC

(collectively, the “Taxpayers”) appeal the Court of Appeals’ decision to uphold the tax

assessment of the Taxpayers’ mineral lands. For the reasons that follow, we reverse.

I. BACKGROUND

EQT Production Company and EQT Gathering, LLC (collectively “EQT”) owned

mineral lands in Wise County, Virginia (the “County”), possessing natural gas reserves. EQT

sold its land to Diversified Production, LLC (“Diversified”) in July 2018 through a bidding

process (the “2018 Sale”).

Pursuant to Code § 58.1-3286, the County levied taxes on the gas wells on the property,

but not the gas reserves, for tax years 2018, 2019, and 2020. The taxed property consisted of 578

gas wells, 187.7 miles of gas pipelines, and 14 gas compressors at 8 stations. To calculate the

tax, the County assessed the fair market value of the gas wells using the cost approach method of

appraisal. 1 The County valued the lands at $134,329,600 for the 2018 and 2019 tax years, and

$104,573,100 for the 2020 tax year.

1 Although this case turns on whether the gas reserves should have been assessed under Code § 58.1-3286, much of the debate has centered around which valuation method is In May 2021, the Taxpayers applied for relief from taxes levied under Code § 58.1-3286

on their mineral lands and the improvements thereon. The Taxpayers alleged that the County

assessed their property in excess of its fair market value. They sought corrections of the

assessments and refunds of the taxes they paid on valuations in excess of the fair market value.

The Taxpayers argued that the County violated Virginia law by only valuing the

improvements on the land, such as the well infrastructure, but not the gas reserves. They

contended that the gas wells have no value without the reserves, and that the well infrastructure

is universally operated as a unit with the reserves. According to the Taxpayers, it is illogical to

value the well infrastructure without the reserves. The Taxpayers further claimed that the

County relied on only one valuation approach, the cost approach, and failed to consider and

properly reject the income or market approach. Conversely, the County maintained that it was

entitled to exclude the gas reserves, and it considered and properly rejected the other approaches.

appropriate when assessing mineral lands such as the one in question. We have previously outlined the three approaches commonly used by taxing authorities for these assessments:

The cost approach estimates the value of property based on the current cost of the asset, minus depreciation or reduced value from physical deterioration, functional obsolescence, and economic obsolescence. The income approach measures market value as the present worth of monetary benefits anticipated to be derived in the future from ownership of the asset. The sales approach calls for an analysis and comparison of recent sales of comparable property.

McKee Foods Corp. v. County. of Augusta, 297 Va. 482, 496 (2019) (internal quotations and citations omitted). “‘Ideally, an appraisal should, if possible, derive its final determination of a property’s value using all three approaches in order to maximize the likelihood that the valuation accurately reflects the property’s fair market value.’” Id. (quoting Keswick Club, L.P. v. County of Albemarle, 273 Va. 128, 137 (2007)). If a taxing authority only uses one approach, the assessment is still entitled to the presumption of correctness if the taxing authority considered and properly rejected the other valuation methods. Id.

2 The County asserted that it did not need to research income or revenue as the well infrastructure

does not generate income.

Along with using the cost approach, the County categorized the property as “special

purpose.” It did not formally research income data because it was valuing non-income

generating assets such as the wells, pipelines, and compressors. The gas reserves were not taxed.

Further, while the County was monitoring sales and was aware of the 2018 Sale, it concluded

that the sale price was significantly below fair market value 2 because of certain impairments and

disparities associated with it. 3 The County also relied on a 2011 trial court opinion and a 2013

agreement between the parties where they agreed to use the cost approach to value the

improvements to the mineral lands at issue in this case. 4

At trial, Steven Sprenger (“Sprenger”), a tax and audit consultant, testified as an expert

for the Taxpayers. Sprenger testified that the preferred method for valuing assets in the oil and

gas industry is “hands down” the income approach as the cost approach is not used to value these

types of assets. Using the income approach, he valued the lands at $32,898,000 for 2018,

2 The trial court referred to the fair market value as the “sale value.” 3 EQT took “large impairments to the assets in the amount of $2.3 billion and $118.1 million.” 4 Prior to the present case, EQT filed an application for correction of the tax assessments involving the same mineral lands at issue here. These assessments were completed by the County for the years 2002-2005. In 2011, the Court utilized the cost approach, which both parties agreed was appropriate. In 2013, the Commissioner entered into an agreement with EQT pertaining to the mineral land taxes. Under those terms, the parties agreed that the County would assess the improvements using the cost approach, whereas the land improved and under development and not under development would be calculated at a flat rate per acre. This approach applied for the years 2014-2017 and would continue unless one of the parties decided to change or terminate the agreement. The Commissioner terminated the agreement in 2017.

3 $22,234,000 for 2019, and $27,212,000 for 2020. Sprenger’s valuation was based on the

estimated amount of natural gas left in the reserves.

Sprenger further explained that gas wells have no value “independent of the mineral

reserves” because “no one is going to pay you for the hole in the ground if that’s [sic] nothing to

get out of it.” The value of gas wells, Sprenger claimed, is not separable from “the reserve

value” because “it’s all associated with the extraction of that commodity.” According to

Sprenger, the cost to reconstruct a well is irrelevant to fair market value because buyers and

sellers only desire the well for the income derived from the reserves attached to the well. He

insisted that, for that reason, the industry uses the income approach to determine the fair market

value of gas wells.

The County called Paul Hornsby (“Hornsby”), a general appraiser, as its expert witness.

Hornsby testified that he independently chose to use the cost approach, explaining that he chose

that approach because he considered the lands “special purpose property,” meaning they are

unique and not adaptable to some other use. According to Hornsby, the International

Association of Assessing Officers (“IAAO”) recommends using the cost approach for special use

properties. He further testified that he chose not to include the gas reserves in his assessment

because he understood them to not have been pled in the petition nor to be part of the subject

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Zinone v. LEE'S CROSSING HOMEOWNERS ASS'N
714 S.E.2d 922 (Supreme Court of Virginia, 2011)
Keswick Club, L.P. v. County of Albemarle
639 S.E.2d 243 (Supreme Court of Virginia, 2007)
Mozley v. Prestwould Board of Directors
570 S.E.2d 817 (Supreme Court of Virginia, 2002)
Gilmore v. Landsidle
478 S.E.2d 307 (Supreme Court of Virginia, 1996)
Hampton Nissan Ltd. Partnership v. City of Hampton
466 S.E.2d 95 (Supreme Court of Virginia, 1996)
City of Winchester v. American Woodmark Corp.
464 S.E.2d 148 (Supreme Court of Virginia, 1995)
Commonwealth v. Shell Oil Co.
169 S.E.2d 434 (Supreme Court of Virginia, 1969)
Town of Ashland v. Board of Supervisors
117 S.E.2d 679 (Supreme Court of Virginia, 1961)
Carter v. Nelms
131 S.E.2d 401 (Supreme Court of Virginia, 1963)
In re: Woodley
777 S.E.2d 560 (Supreme Court of Virginia, 2015)
City of Richmond v. Va. Elec. & Power Co.
787 S.E.2d 161 (Supreme Court of Virginia, 2016)
Miller & Rhoads Bldg., L.L.C. v. City of Richmond
790 S.E.2d 484 (Supreme Court of Virginia, 2016)
Commonwealth v. P. Lorillard Co.
105 S.E. 683 (Supreme Court of Virginia, 1921)

Cite This Page — Counsel Stack

Bluebook (online)
EQT Production Co. v. County of Wise, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eqt-production-co-v-county-of-wise-va-2026.