Santa Fe Energy Co. v. State Board of Equalization

*178 Opinion

Introduction

Plaintiff Santa Fe Energy Company (Santa Fe) appeals from a summary judgment granted in favor of defendant California Board of Equalization (Board) and from the denial of its own motion for summary judgment.

Statement of Facts

On September 9, 1976, Santa Fe Industries, Inc. (Santa Fe Industries), plaintiff’s parent company, entered into an agreement of sale with Westates Petroleum Company (Westates). Westates was engaged in the business of exploration, development and production of crude oil. Santa Fe Industries purchased all of Westates’ assets with the exception of certain excluded assets and assets and properties located outside North America.

The agreement of sale provided that Santa Fe Industries could assign any or all of its rights and duties under the contract to one or more of its wholly owned subsidiaries, and Westates would render performance of its obligations to the subsidiaries. Prior to the closing of the transaction, Santa Fe Industries did assign all of its rights and duties pertaining to California to Chanslor-Western Oil and Development Company (Chanslor-Western), a wholly owned subsidiary. Plaintiff is the successor-in-interest,…