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AMOCO PRODUCTION CO. v. NEWTON SHEEP CO.

Nos. 94-4242, 95-4169.

85 F.3d 1464 (1996)

AMOCO PRODUCTION COMPANY, a Delaware Corporation, Plaintiff-Appellee, v. NEWTON SHEEP COMPANY, a limited partnership, Defendant-Appellant, and United States of America, et al., Defendants. Scott NEWTON; Florence Bentine; Virginia Burke; Jane Ann Holman, trustee of the James Newton Trust; Edna Newton; George Newton; Ralph Newton, individually and as trustee of the Bessy Newton Trust, Plaintiff-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

June 6, 1996.

Attorney(s) appearing for the Case

Dale E. Anderson, Spencer & Anderson, Salt Lake City, Utah (Claron C. Spencer with him on the briefs), for Defendant-Appellant and Plaintiff-Appellants.

Jeffrey E. Nelson, Van Cott, Bagley, Cornwall & McCarthy, Salt Lake City, Utah, for Plaintiff-Appellee.

Gilbert S. Rothenberg and Bridget M. Rowan, Attorneys, Tax Division, U.S. Department of Justice, Washington, DC, on the brief, for Defendant-Appellee.

Before TACHA, BALDOCK, and KELLY, Circuit Judges.

TACHA, Circuit Judge.

The first of these cases began as a suit by Amoco Production Company (Amoco) to quiet title to oil and gas in certain lands in Summit County, Utah. The defendants in that action were originally the United States and its lessees, who claimed title to one-half of the oil and gas, and the Newton Sheep Company (the Newtons), a Utah family limited partnership, and its grantees, who claimed title to all of the oil and gas. In addition, there was a...

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