Standard Oil Co. v. State Board of Equalization

Opinion

ELKINGTON, J.

California’s Revenue and Taxation Code section 6353 provides certain exemptions from taxes imposed by the state’s “Sales and Use Tax Law” (Rev. & Tax. Code, §§ 6001-7176, inclusive). Section 6353, during the period with which we are concerned, read: “There are exempted from the taxes imposed by this part the gross receipts from the sales, furnishing, or service of and the storage, use, or other consumption in this State of gas, electricity, and water when delivered to consumers through mains, lines, or pipes.”

Respondent Standard Oil Company, hereafter “Standard,” had…