Security Data, Inc. v. County of Contra Costa

The County of Contra Costa (County) and the City of Walnut Creek (City) appeal from a judgment refunding certain property taxes to plaintiff and respondent Security Data, Inc. (plaintiff).

Background

Plaintiff is a subsidiary of Security National Bank, a national banking association (hereinafter identified by name or as the bank). At pertinent times, the bank owned certain components designed for use in a computer system. It also owned or controlled an office building located in the County and within the territorial limits of the City. The bank leased the components, and space in the building, to plaintiff. The components were installed in the leased space.

The County classified the components as real property assessed to plaintiff in the tax years 1973-1974, 1974-1975, and 1975-1976. Plaintiff paid the real property taxes consequently imposed in those years. Part of the taxes paid were remitted by the County to the City. Plaintiff subsequently claimed refunds of the taxes; exhausted its administrative remedies; and commenced two separate actions against the County and the City, seeking recovery of the taxes on the ground that the computer components had been…