Midland Central Appraisal District v. BP America Production Company

CourtCourt of Appeals of Texas
DecidedMarch 26, 2009
Docket11-07-00048-CV
StatusPublished

This text of Midland Central Appraisal District v. BP America Production Company (Midland Central Appraisal District v. BP America Production Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Midland Central Appraisal District v. BP America Production Company, (Tex. Ct. App. 2009).

Opinion

Opinion filed March 26, 2009

Opinion filed March 26, 2009

                                                                        In The

    Eleventh Court of Appeals

                                                                 ____________

                                                          No. 11-07-00048-CV

                                                    __________

    MIDLAND CENTRAL APPRAISAL DISTRICT, Appellant/Cross-Appellee

                                                             V.

                      BP AMERICA PRODUCTION COMPANY ET AL,

                                         Appellees/Cross-Appellants

                                         On Appeal from the 238th District Court

                                                        Midland County, Texas

                                   Trial Court Cause No. CV44864 (consolidated)

                                                                   O P I N I O N


The issue in this case is whether an ad valorem tax may be imposed on crude oil located in Midland County in a tank farm that is an integral part of an interstate, common carrier pipeline system.  In its appraisal rolls for 2003 and 2004, Midland Central Appraisal District (MCAD) included oil located in the tank farm on January 1 of the respective years.  MCAD allocated ownership of the oil to various shippers, including BP America Production Company; Amerada Hess Trading Company; Chevron USA, Inc.; ChevronTexaco Products Company; ChevronTexaco Global Supply and Trading Company; TEPPCO Crude Oil LLC; and TEPPCO Crude P/L LLC (hereinafter referred to collectively as the Oil Companies).  The Oil Companies properly protested and ultimately brought four separate suits in district court.  After consolidating the suits and conducting a nonjury trial, the trial court rendered judgment that the oil was not taxable but denied the Oil Companies= request for attorney=s fees.  MCAD appeals the trial court=s ruling regarding the taxability of the oil, and the Oil Companies appeal the denial of attorney=s fees.  We affirm. 

                                                                       I.  Issues

MCAD presents six issues for review.  In the first issue, MCAD contends that the trial court erred as a matter of law in determining that the oil is not taxable in Midland County.  In the second issue, MCAD contends that the trial court erred in finding that oil had no situs in Midland County.  In the third issue, MCAD contends that the trial court erred in holding that the oil was in interstate commerce.  In its fourth issue, MCAD challenges the legal and factual sufficiency of several findings of fact and asserts that the trial court erred in considering the oil as individual barrels rather than an aggregate inventory.  MCAD argues in its fifth issue that the trial court erred in finding that the tax is not applied to an activity or oil with a substantial nexus to Texas.  In its final issue, MCAD asserts that the trial court erred in finding that MCAD=s allocation of ownership of the oil was not reasonable.

The Oil Companies present two issues for review.  In their first issue, the Oil Companies contend that the trial court erred in denying their request for attorney=s fees because the award of attorney=s fees was mandated by statute, specifically Tex. Tax Code Ann. ' 42.29 (Vernon 2008).  In their second issue, the Oil Companies assert that MCAD waived its challenge to the award of attorney=s fees by requesting findings of fact that support the award. 

                                                             II.  Background Facts


The record shows that the underlying facts in this case are largely undisputed.  The unchallenged findings of fact indicate that oil at issue in this case was produced mostly in West Texas and a small amount in eastern New Mexico and was injected into the Midland Pipeline System, a spiderweb configuration of interconnecting pipelines covering more than two dozen counties in West Texas and eastern New Mexico.  The Midland Pipeline System is an interstate, common carrier pipeline system that is regulated by the Federal Energy Regulatory Commission and is operated by various pipeline companies that are not parties to these proceedings.  Upon injection of the subject oil into a pipeline, control and custody was relinquished to the pipeline companies; the oil, being fungible, became part of the common stream of oil.

Oil in the system travels through pipelines in Texas, taking no more than two and one-half weeks, to final destinations at various oil refineries located in Texas and in other states.  During the journey, a large amount of oil passes through the tank farm where the Midland Pipeline System converges.  The tank farm functions as an integral part of the Midland Pipeline System and exists to facilitate the transportation of the oil, not to store oil.  The oil in the tank farm arrives and exits via the Midland Pipeline System.  The time from entry into a tank to exit from a tank is six to seventy-two hours.  However, a certain minimum volume of cushion oil is required to be maintained in each tank for safety reasons and to meet emission standards, resulting in the constant presence of a large amount of oil in the tank farm.  Blending, batching, or staging of the oil may occur at the tank farm as necessary to facilitate the transmission of the oil through the Midland Pipeline System, but these processes do not interrupt the continuity of transit.  The tanks are not used for storage.

Oil is bought, sold, and traded by document transfers irrespective of where the oil may be in the system.  These transfers do not alter the movement of the oil or interrupt its in-transit movement to refineries.  Upon arrival at a refinery, the oil is assessed and listed for taxation by the local appraisal authorities.[1]  Furthermore, ad valorem taxes are assessed on the pipelines, tanks, physical assets, and equipment at the tank farm.  In 2003 and 2004, those ad valorem taxes were timely paid.

                                                              III.  MCAD=s Appeal

A.  Sufficiency of the Challenged Findings.

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Midland Central Appraisal District v. BP America Production Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/midland-central-appraisal-district-v-bp-america-pr-texapp-2009.