Ships & Power Equipment Corp. v. County of San Diego

This action involves the validity of a personal property tax levied for the year 1947-48 upon cer*523tain ships moored in San Diego harbor. The plaintiff paid the tax under protest and brought this action to recover the amount paid.

The cause was heard upon an agreed statement of facts. The plaintiff is a New Jersey corporation, and none of its officers reside in California. On December 4, 1946, it purchased from the United States Navy 33 seagoing vessels, being L. C. I. landing craft constructed for Navy use in transporting infantry troops in assault landings. On January 16, 1947, it purchased…