The following opinion, prepared by SAWTELLE, Circuit Judge, is adopted as the opinion of the court by WILBUR and GARRECHT, Circuit Judges:
During the period involved in the instant case, the Motor Vehicle Fuel Tax Acts of California provided that every distributor should pay a 3-cent license tax on each gallon of motor vehicle fuel sold and distributed in the state. Pursuant to those acts, the state filed its claim against the receivership estate of Producers &...
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