Kamilche Company Simpson Redwood Co. v. United States

In this federal corporate income tax refund case, we must decide whether judicial determination of ownership of one portion of real property collaterally estops the United States from challenging title to the entire property.

I

This case arises from a boundary dispute involving lands owned by the Simpson Redwood Company and the State of California. The disputed boundary runs in a diagonal, stair-step fashion from northwest to southeast through township 12 north, range 1 east (“township 12-1”) in Humboldt, California and divides land owned and logged by Simpson, to the east, from Prairie Creek State Park, to the west.

In 1882, S.W. Foreman surveyed township 12-1 (the “Foreman survey”). Four years later, John Gilcrest surveyed the adjoining township 12-2 (the “Gilcrest survey”). Under the Gilcrest survey, the boundary at issue was situated to the north and east of the boundary as identified in the Foreman survey. This inconsistency created a hiatus between the boundary lines of the State Park and • what was later to become Simpson’s property. Under the Foreman survey, the land in this hiatus belonged to Simpson’s predecessors; under the Gilcrest survey, the land was part of the…