The Texas Third Court of Appeals just issued its opinion in Southwest Royalties, Inc. v. Combs, No. 03-12-00511-CV. The opinion affirms a district court opinion denying oil and gas operators the Texas sales tax manufacturing exemption on their purchases of certain above-ground and downhole production equipment. The opinion also provides some useful discussion of the circumstances under which the Texas Comptroller’s statutory interpretations should be accorded deference. We will soon post a longer blog entry discussing this opinion and its implications for Texas taxpayers in more detail.
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