United States v. California and California State Board of Equalization (507 U.S. 746)
U.S. Supreme Court · decided April 26, 1993 · Supreme Court Database (Spaeth)
- Citation
- 507 U.S. 746 · 113 S. Ct. 1784
- Decided
- April 26, 1993
- Term
- October Term 1992
- Vote
- 9–0
- Majority author
- Justice O'Connor
- Issue area
- Judicial Power
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice O'Connor delivered the opinion of the Court. This is another in the long line of cases, beginning with McCulloch v. Maryland, 4 Wheat. 316 (1819), in which the Federal Government asks this Court for relief from what it considers illegal state taxes. Unlike the typical tax immunity case, however, we are not presented with a claim that the state tax is unconstitutional; instead, the question is whether the Federal Government may recover taxes it claims were wrongfully assessed under California law against one of the Government’s private contractors. I The United States has established three Naval Petroleum Reserves in California and Wyoming, one of which is Naval Petroleum Reserve No. 1, located in Kern County, California. 10 U. S. C. § 7420. First through the Department of the Navy and later through the Department of Energy, the United States contracted with Williams Brothers Engineering Company (WBEC) to manage oil drilling operations at Reserve No. 1 from 1975 to 1985. Under the contract, WBEC received an annual fixed fee plus reimbursement for costs, which the contract defined to include state sales and use taxes. California assessed approximately $14 million in sales and use taxes, pursuant to Cal. Rev. & Tax. Code Ann. §6384 (West 1987), against WBEC for the years 1975 through 1981. The State informed WBEC of the tax deficiencies through two notices, one issued in…
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