Legal Opinion

United States v. State of California and California State Board of Equalization

Court of Appeals for the Ninth Circuit

Decided May 16, 1991No. 89-15833PublishedCited by 27 opinions

1Opinion of the Court

HATTER, District Judge:

FACTS

The United States, through the Departments of the Navy and Energy, contracted with Williams Brothers Engineering Company [“WBEC”] to manage oil drilling operations on federal land in California. California assessed WBEC $14 million in sales and use taxes for the years 1975 through 1981. The assessments were made pursuant to section 6384 of California’s Revenue & Taxation Code, which imposes sales and use taxes against federal construction contractors. WBEC was informed of the assessments through notices of tax deficiencies issued in 1978 and 1982.

WBEC paid the…

2Cases cited18 opinions

  1. Fu-Kong Tzung Jean Tzung v. State Farm Fire and Casualty Company, and Does 1 Through 100, InclusiveCourt of Appeals for the Ninth Circuit · 1989
  2. Wallis v. Pan American Petroleum Corp.Supreme Court of the United States · 1966
  3. United States v. New MexicoSupreme Court of the United States · 1982
  4. Ruby Humphreys, Administratrix of the Estate of William Orvie Humphreys, Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1959
  5. United States v. John Hancock Mutual Life InsuranceSupreme Court of the United States · 1960

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3Cited by27 opinions

  1. United States v. Westlands Water DistrictDistrict Court, E.D. California · 2001
  2. United States v. CaliforniaSupreme Court of the United States · 1993
  3. Cardenas v. AnzaiCourt of Appeals for the Ninth Circuit · 2002
  4. Peter J. Bresson (Transferee),petitioner-Appellant v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
  5. Novato Fire Protection District v. United States of America U.S. Coast GuardCourt of Appeals for the Ninth Circuit · 1999

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