Municipality of Anchorage, formerly d/b/a Municipal Light & Power Department v. State of Alaska, Department of Revenue

Summary

The court affirmed the superior court’s judgment upholding the Department of Revenue’s calculation of Anchorage’s natural-gas tax credits. It held that municipal own-use gas must be treated as taxable production for credit calculations because the statutory text is ambiguous, while legislative history and the tax-credit scheme’s purposes favor calculating credits from gas defined as taxable under the general statute. The court also held that the Department could apply that interpretation without formal rulemaking because it was foreseeable, added no substantive requirements, and did not change an official agency policy.