Rand Corp. v. County of Los Angeles

Rand Corporation is a nonprofit California corporation engaged in research and education for the United States of America relating to military preparation and effectiveness. The corporation owns a building on privately owned land in Santa Monica in Los Angeles County. In 1956 and 1957 the building contained a Johnniac computer which Rand had constructed for the government, a telephone network, an Ozalid Printmaster, motor generators and other equipment, all the property of the government. In 1956 and 1957 the County of Los Angeles made assessment of the possessory interest of Rand in and to the property of the government. A small amount of it was personal property, the remainder was permanently affixed to the land and was realty. Taxes were levied and were paid by Rand, a part being the share of the City of Santa Monica, a part the share of the City of Los Angeles and the remainder being due to the county. Claiming the taxes were invalid Rand made demand upon the county for refund, which was denied. The present action is against the county and the two cities for refund.

The judgment awarded plaintiff the amount of the taxes paid upon the possessory interest in the personal…