McKendry

Plaintiffs, E. S. McKendry and Urner Broadcasting Co., in these consolidated actions, appeal from a judgment on the pleadings in favor of defendants.

In 1980 and 1981, Kern County embarked upon a campaign of recording tax liens for old unsecured personal property tax claims, which were unpaid according to the county’s records. Under Revenue and Taxation Code section 2191.3, where a tax on unsecured property has been assessed and such tax has become delinquent: “The tax collector may file for record without fee in the office of the county recorder of any county a certificate specifying the amount due, the name, federal social security number, if known, and last known address of the assesses liable for the amount, and the fact, if such be the fact, that all provisions of this division in the computation and levy of the tax have been complied with.” Upon recording a certificate of delinquency pursuant to Revenue and Taxation Code section 2191.3, the amount of the deficiency constitutes a lien on all personal and real property in the county owned by the assessee named in the certificate or acquired by the assessee before the lien expires. The lien has the force and effect of…