Hopkins

Appellant seeks to recover from respondents, by this action, the amount of certain taxes assessed against its property for the year 1924, and which it paid under protest. Appellant claims that it should have been credited against the assessed valuation of said property with $383,300, unsecured promissory notes owing to residents of this state and $300,000 owing by it to certain banks upon unsecured promissory notes executed by it to them. At the trial the case was submitted to the court upon a stipulation of facts and these stipulations were adopted as a part of the findings. The said stipulated facts are brought up on this appeal by a bill of exceptions.

It appears from the stipulated facts that on the first Monday in March, 1924, at the request of respondent, Ed. W. Hopkins, who was the assessor for the county and city of Los Angeles, appellant made a statement of its taxable property, real and personal, owned by it at that date.

The said assessor refused to accept the statement of the appellant and thereupon made an independent investigation of appellant’s business and property. The result of that investigation was that he refused to allow appellant a dedue tion from the…