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SOUTHWEST EXPLORATION CO. v. RIDDELL

No. 19960.

362 F.2d 833 (1966)

SOUTHWEST EXPLORATION CO., by Signal Oil & Gas Company, successor through liquidation, Appellant, v. Robert A. RIDDELL, District Director of Internal Revenue, Los Angeles, California, Appellee.

United States Court of Appeals Ninth Circuit.

June 22, 1966.

Attorney(s) appearing for the Case

Dana Latham, John H. Hall, David H. Vena, Los Angeles, Cal., for appellant.

John B. Jones, Jr., Acting Asst. Atty. Gen., Meyer Rothwacks, Gilbert E. Andrews, Robert A. Bernstein, Attys., Dept. of Justice, Washington, D. C., Manuel L. Real, U. S. Atty., Loyal E. Keir, Asst. U. S. Atty., Chief, Tax Div., Los Angeles, Cal., for appellee.

Before KOELSCH and ELY, Circuit Judges, and BEEKS, District Judge.

KOELSCH, Circuit Judge:

This is an appeal from a judgment of the district court denying a taxpayer's claim for an income tax refund. The opinion appears in 232 F.Supp. 13 (1964).1

In 1938 Southwest Exploration Co. was granted leases of certain oil lands lying off the coast of the State of California. The then State law, enacted to protect beaches and fishing, permitted off-shore oil to be extracted...

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