Wayne County School District v. Mississippi Department of Revenue, 224 So. 3d 539

Wayne County School District (WCSD) sought a refund of severance taxes paid on oil and gas royalties from sixteenth-section lands; total refund claim was $2,345,560.
The Mississippi Department of Revenue (MDOR) denied the initial refund claim, prompting litigation and related proceedings.
The Mississippi Supreme Court decided in Jones County Sch. Dist. v. Dep’t of Revenue that school districts are not liable for severance taxes on sixteenth-section royalties and that no statute of limitations barred refund claims.
After Jones County, MDOR agreed to refund WCSD and began payments in January 2014; WCSD also sought interest on the overpayment.
The chancery court held MDOR must pay interest at 1% per month beginning 90 days after the Mississippi Supreme Court’s Jones County opinion (i.e., starting June 5, 2013) and entered judgment for additional interest; MDOR paid that amount and WCSD appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. When does interest begin under Miss. Code Ann. § 27-65-53?	Interest begins 90 days after WCSD filed its refund application.	Interest begins 90 days after MDOR finalizes the refund amount; MDOR conceded the more accurate date was the Supreme Court ruling.	Start date is 90 days after the later of filing or the commissioner’s determination; here that was 90 days after the Supreme Court’s Jones County opinion.
2. Does § 27-65-53 require interest where the commissioner’s determination is based on a court ruling?	WCSD argued statute requires interest once 90 days from filing expired.	MDOR argued determination must be a commissioner action and not necessarily triggered by court rulings.	Statute’s plain language covers determinations including those arising from court rulings; interest applies based on the later triggering date.
3. How should MDOR allocate payments between interest and principal ("United States Rule" vs. alternative)?	WCSD urged a specific allocation method (implied United States Rule).	MDOR had a different allocation approach.	Court did not reach this issue because statutory interpretation disposed of the case.
4. Should additional interest be awarded under MRAP 37 if allocation freezes interest at last payment?	WCSD sought additional interest if allocation reduced accruing interest.	MDOR opposed additional interest.	Not addressed—unnecessary given resolution on § 27-65-53 timing.

Jones County Sch. Dist. v. Dep’t of Revenue, 111 So. 3d 588 (Miss. 2013) (held school districts not liable for severance taxes on sixteenth-section royalty interests and no statute-of-limitations bar for refunds)
Natchez Equip. Co., Inc. v. Gibbs, 623 So. 2d 270 (Miss. 1993) (standard: de novo review for legal questions)
Miss. Dep’t of Transp. v. Allred, 928 So. 2d 152 (Miss. 2006) (courts must apply unambiguous statutes according to plain meaning)
Green v. Cleary Water, Sewer & Fire Dist., 910 So. 2d 1022 (Miss. 2005) (courts cannot restrict or enlarge unambiguous statutory language)
City of Natchez v. Sullivan, 612 So. 2d 1087 (Miss. 1992) (statutory interpretation focuses on discernment and effectuation of legislative intent)