Craig Corp. v. County of Los Angeles

This appeal is from a summary judgment granted to plaintiffs on their complaint for recovery of ad valorem property taxes paid under protest. The ground of the decision was that the court did not believe that the declaration of the defendants raised any triable issue of fact.

The plaintiffs, Craig Corporation, Citizens America Corporation, Inter-Pacific Corporation, and Trend of the Times, Inc., are importers and had imported goods in the County of Los Angeles on tax lien date, March 1, 1973. The goods arrived in containers at plaintiffs’ individual warehouses, where they were unloaded and stored.

Import immunity was denied plaintiffs on the goods in question. Prior to filing immunity claims, plaintiffs received a written bulletin from the Los Angeles County Assessor’s office directing that all goods arriving in cargo containers and unloaded therefrom on tax lien date were not immune from ad valorem property tax on the ground that the cargo container constituted the original package and that the opening and unloading therefrom constitutes a “breaking of the bulk.” The policy was premised upon language in Volkswagen Pacific, Inc. v. City of Los Angeles (1972) 7 Cal.3d 48…