Schettler

—Plaintiff Ernest B. Schettler, doing business as Golden Gate Company (hereinafter appellant) appeals from the judgment dismissing the action pursuant to the order of the trial court granting respondent’s motion for summary judgment. The pertinent facts are included in an agreed statement and may be summarized as follows.

The instant lawsuit was brought to recover ad valorem property taxes imposed on imported inventory owned by appellant on March 1, 1972. On that date the goods were in the possession of appellant as the original importer, were held for resale and kept unopened in their original package. As the law was interpreted at that time, such goods were immune from local taxation (U.S. Const., art. I, § 10, cl. 2; Brown v. Maryland (1827) 25 U.S. (12 Wheat.) 419 [ 6 L.Ed. 678 ]; Low v. Austin (1871) 80 U.S. (13 Wall.) 29 [ 20 L.Ed. 517 ]; Simon v. County of Los Angeles (1956) 141 Cal.App.2d 74 [ 296 P.2d 381 ]; Sterling Liquor Distributors, Inc. v. County of Orange (1970) 3 Cal.App.3d 510 [ 83 Cal.Rptr. 571 ].) In accordance therewith, appellant was advised by respondent that the imported goods were immune from local taxation so long as they retained their…