El Tejon Cattle Co. v. County of San Diego

Plaintiff appeals from an adverse judgment in its action to recover property taxes paid under protest for the tax years 1961-62 and 1962-63 on its possessory interest in some 40,000 acres of tax-exempt land in San Diego County. As will appear, we have concluded that the trial court correctly *429 determined that the method employed by the county assessor and approved by the county board of equalization was proper and permissible under the circumstances, and, further, that no attempted taxation of exempt property was shown. The judgment will therefore be affirmed.

Fee title to the involved land is held by Vista Irrigation District, a public agency, and is tax-exempt. In September 1960, following competitive bidding, plaintiff was awarded a five-year lease thereof for grazing purposes for a total of $240,000, payable $4,000 per month ($48,000 per year), with options to renew the lease for two additional five-year terms.

The lease imposes various restrictions on plaintiff, including limiting plaintiff’s use to the “grazing by cattle of native or cultivated forage crops, including all annual or perennial plants or shrubs, and for the supplemental or finished feeding of cattle.” The…