No. 89-15833.

932 F.2d 1346 (1991)

UNITED STATES of America, Plaintiff-Appellant, v. STATE OF CALIFORNIA and California State Board of Equalization, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided May 16, 1991.

Attorney(s) appearing for the Case

Gary R. Allen, David English Carmack, John J. McCarthy, Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff-appellant.

Robert D. Milam, Deputy Atty. Gen., Sacramento, Cal., for defendants-appellees.

Before ALARCON and POOLE, Circuit Judges, and HATTER, District Judge.

HATTER, District Judge:


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...

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