Perluss

Coast Oyster Company, a corporation, appeals from a judgment rejecting its claim for a refund of unemployment insurance taxes.

The essential facts were stipulated to by the parties. Briefly they are: Appellant was and is a Washington corporation engaged in the business of raising and selling oysters and oyster products. During the period involved herein, January 1, 1956, through December 31, 1958, appellant was engaged in its business of raising and selling oysters in Humboldt County. It operated oyster beds in Humboldt Bay and maintained two plants, one for fresh packing oysters and one for canning oysters, and offices in Eureka for its California operations.

Appellant’s method of operation was as follows: It deposited oyster seed on its oyster beds; performed such tasks as were necessary for the protection of the beds and oysters; harvested the oysters; loaded the oysters on floating equipment owned by it; transported the oysters to its plants; and then opened, cleaned, graded, and packed or canned the oysters. The smaller oysters were fresh packed by appellant in containers with plastic tops. The oysters which were not suitable for fresh packing were cleaned, washed, graded…