Collins Electrical Co. v. County of Shasta

Plaintiff appeals from the judgment in favor of defendant, denying plaintiff the return of taxes paid under protest.'

Plaintiff contends (1) the property sought to be taxed herein is an improvement to real property which must be taxed to the owner of the real property; (2) the Shasta Dam Area Public Utility District, not plaintiff, is the owner of said property; and (3) if it had a taxable interest in personal property, that interest would merely be the right to receive income or a solvent credit.

Facts

The parties stipulated to the following facts:

Plaintiff is a corporation with its principal place of business in San Joaquin County. On December 11, 1962, the Shasta Dam Area Public Utility District (hereinafter referred to as District) called for bids for the construction of an electric power transmission line from the Keswick switch yard in Shasta County to the District’s facilities near Central Valley in said county, and a substation to be situated at the District’s facilities, near Central Valley in said county. The call for bids impliedly contemplated that title to the electric power transmission lines and the title to the substation would vest in the contractor,…