Wilkinson

Plaintiff (as purchaser under an agreement of sale with the' Department of Veterans Affairs of the State of California) brought an action to quiet title to an alleged full equitable estate in certain property against numerous defendants allegedly seeking interests in or liens against that property. She has appealed from a judgment which upheld the claimed lien of the State Board of Equalization for unpaid use taxes due from plaintiff’s former co-tenant who had quitclaimed his interest to her.

The trial court expressly found, “This action was tried and submitted by both sides on the theory that the only issue involved is the legal question of whether or not a lien filed under Revenue and Taxation Code section 6757 attaches to an equity possessed by the taxpayer under a contract for the purchase of real property entered into between the Department of Veterans Affairs and the taxpayer.” Plaintiff contends on appeal that the trial court erred in finding that it did. It is concluded that the judgment of the trial court was correct and must be affirmed.

The court found that in 1958 plaintiff and defendant Eric F. Wilkinson, as purchasers, entered into an “Agreement of Sale of…