Salyer Land Company v. County of Kings

In 1957 appellant obtained a barley crop loan from the Commodity Credit Corporation (hereinafter CCC) and executed in its favor a note and loan and warehouse receipts pledge agreement. A California state law in effect in 1958 imposed for that year a personal property tax on stored barley against those who owned the barley on the tax levying date. Appellant timely filed its verified statement of property owned by it on the 1958 tax levying date, omitting therefrom 34,-865 tons of the appellant’s warehoused and pledged barley.

Respecting that barley, before the tax-levying date, appellant delivered its purported loan nonpayment intent notice and its purported surrender and quitclaim of its title to the CCC which promptly repudiated that action on appellant’s part, because appellant did not comply with the agreed conditions of loan maturity acceleration and of title surrender.

On the tax levying date and before the agreed loan maturity date, but subsequent to appellant’s purported notice of loan nonpayment intent and purported quitclaim and title surrender, appellee Kings County levied a $27,182.61 tax under that California state law against appellant as the owner of the 34,-865…