Post Oak Oil Co. v. Oklahoma Tax Commission

1978 OK 20, 575 P.2d 964, 60 Oil & Gas Rep. 319, 1978 Okla. LEXIS 310
CourtSupreme Court of Oklahoma
DecidedFebruary 21, 1978
Docket51662, 51669
StatusPublished
Cited by10 cases

This text of 1978 OK 20 (Post Oak Oil Co. v. Oklahoma Tax Commission) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Post Oak Oil Co. v. Oklahoma Tax Commission, 1978 OK 20, 575 P.2d 964, 60 Oil & Gas Rep. 319, 1978 Okla. LEXIS 310 (Okla. 1978).

Opinion

LAVENDER, Vice Chief Justice.

For the purpose of this opinion, the two original actions are consolidated since the constitutionality of the same levied tax is involved, the conservation excise tax. 68 O.S.Supp.1977, §§ 1107 et seq. 1

Petitioner, Post Oak Oil Company (Post Oak), is an Oklahoma corporation that pro *966 duces gas in Oklahoma. That gas is sold in both intrastate and interstate commerce. Petitioner, Forrest Rozzell (Rozzell) is a Little Rock, Arkansas, resident and consumer of gas produced in Oklahoma and repurchased by him from a purchaser buying in interstate commerce from Oklahoma gas producers. Respondent in each action is the Oklahoma Tax Commission, the state agency authorized to enforce the tax.

The attack on the constitutionality of the conservation excise tax comes under the federal constitution as an undue burden on interstate commerce. Petitioner, Post Oak, principally argues the formula for calculating the amount of the levied tax is discriminatory to interstate commerce. § 1108 A. Petitioner, Rozzell, principally argues discrimination when the tax is considered with credits for excise taxes levied by the state on produced minerals, including gas, allowed against any Oklahoma state income tax. 68 O.S.Supp.1977, § 2357 D. 2

Tax Commission contends the tax to be on the local state act of severance or production of gas without regard to sale in intrastate or interstate commerce that occurs after severance and after the levying of the tax. Commission says any income tax credit goes to all producers 3 of Oklahoma gas, but to them only. Of necessity, these producers have Oklahoma state income and earn credit against that income tax, coming from actual payment of the conservation excise tax, without regard to producer’s residence, within or without of this state. It sees no discrimination in the tax.

First, we examine the jurisdiction of this court over the controversy, here. All parties agree on the jurisdiction of this court and urge this court to exercise its discretion in assuming original jurisdiction.

*967 Involved is the collection by a state commission of a conservation excise tax relating to a valuable natural resource of this state. The additional new revenue to the state from the yield of the conservation excise tax is approximated as some forty million dollars during 1978. This court has general superintending control over commissions of this state created by law. Okl.Const. Art. 7, § 4. This includes the Tax Commission. We conclude the effect of the newly generated tax on the production of gas, a natural resource of this state, and the effect on the fiscal affairs of this state’s government make the validity of the called-into-question tax a matter of general public importance. We follow the rationale of Wiseman v. Boren, Okl., 545 P.2d 753 (1976) and court syllabus of State v. Mathews, 134 Okl. 288, 273 P. 352 (1928). That syllabus said:

“Where the constitutionality of an act is questioned and is of such general public importance that there is a general public need for a speedy determination of its constitutionality, this court, in its discretion, will assume original jurisdiction of the question of its constitutionality. * * ⅜ ft

We assume original jurisdiction of the question of the constitutionality of the conservation excise tax.

An abstract of the conservation excise taxing statute shows:

The legislative intent is to levy the tax on the act of severance, § 1107;
The levy is on all 4 natural gas and/or casinghead gas produced including both working interest and royalty interest, §§ 1108, 1110;
Liability for the tax attaches only to the producers and made a first lien on their property, both real and personal, § 1110; If a producer is reimbursed by his purchaser for the tax, then remittance of the tax by the purchaser is to the commission and not the producer, § 1108 C;
Requiring the purchaser to remit that portion of tax the producer is reimbursed by the purchaser does not release the producer from tax liability, if the purchaser fails to remit, § 1110; and
The amount of tax is calculated as seven cents on each thousand cubic feet (MCF) of produced gas less seven percent of the gross value of that MCF of produced gas with the levied tax not to exceed one-third of the gross value of that MCF of produced gas, nor shall the levied tax be less than zero. § 1108 A.

Under the calculating formula, the seven cents is offset when the gross value of the MCF of produced gas reaches one dollar and the limitation as to one-third of the gross value comes into play when the gross value of the MCF of produced gas is seventeen and one-half cents. The levied tax operates on the production of gas having a gross value per MCF between one dollar and seventeen and one-half cents with the amount of tax increasing as the value of produced tax decreases. Post Oak argues a two tier pricing system of unregulated gas prices in intrastate selling and federally regulated lower gas prices in interstate selling places more tax and a greater burden on gas entering interstate commerce.

We have given close judicial scrutiny of the levied tax. The excise tax is on the act of severance, and the production, of an Oklahoma natural resource. Severance can occur only once and in this state. The levy is prior to entrance of any gas into interstate commerce and is on all gas so severed and produced without regard to subsequent entrance into either intra or interstate commerce.

A tax of similar nature was found constitutional in Oliver Iron Mining Co. v. Lord, 262 U.S. 172, 43 S.Ct. 526, 67 L.Ed. 929 (1923). This involved an occupational tax, or excise tax, levied by the state on iron ore mined in Minnesota. The United States Supreme Court found the extraction to be a local business subject to local tax even though most of the ore was subsequently shipped in interstate commerce with practi *968 cally no break in the continuity from severance until the beginning of interstate commerce. There, the tax was computed on the value of the ore when brought to the surface. Amount of royalty, which might vary by the mining contract or lease, was allowed to be deducted to arrive at the taxable value. The decision refused to find an undue burden on interstate commerce, for the effect of the tax was indirect. Nor was the tax stricken for some production, due to variance in the royalty amount, might carry a higher tax load through entering interstate commerce.

In the present case, the tax is upon the local act of severance.

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Bluebook (online)
1978 OK 20, 575 P.2d 964, 60 Oil & Gas Rep. 319, 1978 Okla. LEXIS 310, Counsel Stack Legal Research, https://law.counselstack.com/opinion/post-oak-oil-co-v-oklahoma-tax-commission-okla-1978.