Atlantic Richfield Co. v. County of Los Angeles

Summary of the Case

Respondent oil companies brought an action in the Superior Court of Los Angeles County seeking to recover property taxes paid-under protest. This matter was before Division One of this court in Atlantic Richfield Co. v. County of Los Angeles (1977) 68 Cal.App.3d 105 [ 137 Cal.Rptr. 84 ] (ARCO II). Division One reversed the trial court’s determination that Revenue and Taxation Code sections 107.2 and 107.3 were unconstitutional. Upon remand to the trial court, the sole issue tried and determined was whether sections 107.2 and 107.3 were applicable to the 1967-1968 tax year. The trial court determined that these sections were applicable to the 1967-1968 tax year and gave judgment to the respondents for refund of the portion of the taxes paid under protest commencing with the 1967-1968 tax year together with accrued interest. Appellants’ appeal contends that the Legislature did not intend that these sections be applicable to the 1967-1968 tax year, but if applicable, the refund of such taxes which had become vested would constitute an invalid gift of public funds.

Facts

Before 1963, assessors in California assessed the oil lessee’s possessory interest…