Chevron U.S.A., Inc. v. State Bd. of Equalization

Opinion

VOGEL (Miriam A.), J.

This is a tax case, in which the question is whether Platform Gail, a partially built oil drilling platform, was “delivered” to its purchaser when the original builder’s cost overruns and other construction problems required a mid-construction switch to a new builder. Our answer is “no,” which means Platform Gail was not delivered within this state, which in turn means there was no taxable event for California sales tax purposes, which in turn means we reverse the trial court’s judgment, with directions to enter judgment for the purchaser.

Facts

Chevron U.S.A., Inc.,…