Court of Appeals for the Ninth Circuit June 30, 1983, No. 82-4535 (Shell Petroleum, N.V. v. Graves)

TRASK, Circuit Judge.

Shell Petroleum N.V. (SPNY) appeals the dismissal of its action for declaratory and injunctive relief. Pursuant to 42 U.S.C. § 1983 (1976), SPNV sought to enjoin the California Franchise Tax Board from assessing taxes based on a “unitary” business formula against two companies in which SPNV was the majority stockholder.