Miss. State Tax Comm'n v. Murphy Oil USA, Inc


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Docket Number: 2003-CA-00325-SCT
Linked Case(s): 2003-CA-00325-SCT ; 2003-CA-00325-SCT ; 2003-CA-00325-SCT

Supreme Court: Opinion Date: 05-26-2005
Opinion Author: Smith, C.J.
Holding: Reversed and Rendered

Additional Case Information: Topic: Tax assessment - Standard of review - Administrative agency
Judge(s) Concurring: Waller and Cobb, P.JJ., Easley, Carlson, Dickinson and Randolph, JJ.
Non Participating Judge(s): Diaz, J.
Dissenting Author : Graves, J.
Procedural History: Admin or Agency Judgment

Trial Court: Date of Trial Judgment: 01-21-2003
Appealed from: Simpson Chancery Court
Judge: J. Larry Buffington

Note: Link inactive

  Party Name: Attorney Name:  
Appellant: Mississippi State Tax Commission








 

Appellee: Murphy Oil USA, Inc  

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Topic: Tax assessment - Standard of review - Administrative agency

Summary of the Facts: In 1999, the Mississippi State Tax Commission examined the Mississippi Combined Income and Franchise tax returns of Murphy Oil U.S.A., Inc. for the following tax years: 1995, 1996, and 1997. As a result of this examination, the Commission assessed additional franchise taxes and interest against Murphy in the amount of $87,952. After two internal agency appeals, Murphy sought judicial review. The chancellor ordered that the additional franchise tax assessment made by the Commission not be allowed. The Commission appeals.

Summary of Opinion Analysis: When an administrative agency has performed its function, and has made the determination and entered the order required of it, the parties may then appeal to the judicial tribunal designated to hear the appeal. The appeal is a limited one, however, since the courts cannot enter the field of the administrative agency. The court will entertain the appeal to determine whether or not the order of the administrative agency was supported by substantial evidence, was arbitrary or capricious, was beyond the power of the administrative agency to make, or violated some statutory or constitutional right of the complaining party. In this case, the chancery court clearly did not adhere to the correct standard of review. The court reweighed the evidence. The court never found that the Commission’s assessment was not supported by substantial evidence, was arbitrary or capricious, was beyond their power to make or violated some statutory or constitutional right of the party. In fact, there was sufficient evidence in the record to support the Commission’s decision.


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