1 Getty Oil Company (Getty) is a Delaware Corporation engaged primarily in oil production throughout the United States and other countries, qualified to do business in Oklahoma. Getty paid, under protest, an additional assessment of $58,000.00 in Oklahoma income taxes for the taxable year of 1971. Getty was disallowed a carryover deduction claimed on its 1971 Oklahoma tax return for net operating losses sustained in the previous five years. The Oklahoma Tax Commission (Commission) after a hearing denied the protest and Getty appeals.
