Rice Growers' Ass'n of California v. County of Yolo

The county appeals a judgment, whereby plaintiff association was held entitled to recover general taxes, paid under protests, in the aggregate sum of $89,993.96. The sole issue is whether the rice so taxed was or was not an “export” at the time of taxation. If it was, then the taxation was prohibited by article I, section 10, clause 2, of the United States Constitution. If it was not, the county is entitled to retain the sums collected. Although the trial court purported to make findings of fact, the facts were stipulated and hence none were required. This court is therefore presented with questions of law alone, and makes its own construction of the stipulated facts. (Chase Brass & Copper Co. v. Franchise Tax Bd. (1970) 10 Cal.App.3d 496, 502 [ 87 Cal.Rptr. 239 ], hg. den., cert. den. 400 U.S. 961 [ 27 L.Ed.2d 381 , 91 S.Ct. 365 ]; Crawford v. Imperial Irrigation Dist. (1927) 200 Cal. 318, 335 [ 253 P. 726 ]; Export Leaf Tobacco Co. v. County of L.A. (1949) 89 Cal.App.2d 909, 916 [ 202 P.2d 622 ].)

The joint stipulation of facts may be summarized as follows: Respondent is a non-profit corporation existing under the laws of this state engaged exclusively in the operation…