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Mr. Bruce Cartwright

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Sweetwater County
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    OSCN Found Document:BP AMERICA PRODUCTION COMPANY,... - [Cached Version]
    Published on: 3/14/2006    Last Visited: 3/17/2006  

    12. Mr. Bruce Cartwright, the former tax representative for Petitioner, hypothesized the 66/34 split was based on a lease acreage basis of 40 acres per production well.
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    16. The well grouping report was introduced and admitted on the testimony of Mr. Cartwright who neither prepared nor filed the document, nor wrote the "alleged notation," nor witnessed its preparation, nor had any personal knowledge concerning when the notes in the document were made, nor had any personal knowledge about the processes that the DOR followed in 1981 concerning the submission and return of the well grouping report. [Transcript Vol.2, pp.27, 32, 163, Exhibit 137].Mr. Cartwright was not employed by Petitioner at the time the well grouping report was filed, nor could he explain what the DOR did with the form. [Transcript Vol.2, p. 163].Although Mr. Cartwright testified he saw two copies of the well grouping report, and one was stamped by the DOR, Petitioner failed to introduce the stamped copy at the hearing. [Transcript Vol.2, pp.39-40].
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    28. Prior to the passage of Wyoming Statute § 39-2-201(j) and before the Petitioner responded to the DOR, the tax representative for Petitioner, Mr. Bruce Cartwright, claimed to have consulted with the Chairperson of the SBOE. [Transcript Vol.2, pp.55-56].It was Mr. Cartwright's understanding that pending legislation would affect Petitioner's tax liability for the mis-allocated reports. [Transcript Vol.2, pp.58-59].No exhibits or writings were introduced to corroborate Mr. Cartwright's memory.
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    55. Mr. Cartwright testified that a past Chairman of the SBOE thought Wyoming Statute § 39-2-201(j) would apply retroactively to the case at hand. [See Finding of Fact No. 21].
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    Under cross-examination by counsel for Sweetwater County, the Petitioner's tax representative, Mr. Cartwright, admitted the 66/34 allocation used for 1980 through 1983 had nothing to do with the volumes produced from the wells in the specific groups.He likewise admitted the allocation had nothing to do with hydrocarbon pore volume analysis nor with any ratio of producing wells to the total number of wells contained in the Wertz Dome Unit.Moreover, he admitted that the company's reports for 1984 through 1985 were in error. [See Finding of Fact 11].

    67. Mr. Cartwright attempted to explain the 66/34 ratio by stating that it was derived from a calculation based on the amount of acreage in the Wertz Dome Unit that lies within a particular county.He testified he personally had not made that calculation and was unable to do so without the notes of someone else who had made the calculation.He also testified that by attributing a 40 acre parcel to each well in the Unit, he had arrived at approximately a 60/40 split, although he admitted this rough calculation was many years after the tax years in question and the unit had changed substantially.
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    (Letter from Peterson to Cartwright of 12/14/89.)
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    9 at 111, and testimony from Bruce Cartwright, Amoco's former taxation representative, at R. Vol.10 at 41-42).

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