Crowley Launch & Tugboat Co. v. County of Los Angeles

This is an appeal from a judgment of the superior court granting respondent a refund of personal property taxes paid upon the tugboat Navigator for the taxable years 1961 and 1962. We reverse the judgment.

The essential facts controlling determination of the issue presented by the case at bench are not in dispute. They are precisely and cogently set forth in a memorandum opinion of the trial judge which we here adopt in part. During the pertinent period of time, Navigator was employed almost exclusively as a harbor tug. For inbound ships, her services usually began in the outer harbor of Los Angeles or Long Beach. When a cargo or passenger vessel arrived in the outer harbor, Navigator and perhaps other tugs would be made fast to the ship. The tugs would then assist the ship in navigating the waters and channels of the harbor. Upon arrival at the ship’s assigned berth, the tugs would assist her in coming alongside the dock preparatory to mooring. After the vessel was safely moored, the tugs would proceed to other work. Navigator and other tugs were also used to assist *439 ships in undocking and in navigation of the channels and other waters of the harbor at the…