Wells National Services Corp. v. County of Santa Clara

Opinion

TAYLOR, P. J.

Wells National Services Corporation, the taxpayer, appeals from an adverse judgment in its action to recover taxes paid under protest, contending that pursuant to the written agreements for providing television rental services to patients, its interest in the premises owned by the County Hospital District was not a taxable possessory interest, as defined by Revenue and Taxation Code section 107. We have concluded that the judgment in favor of the county must be affirmed.

The matter is before us on an agreed stipulation of facts that may be summarized as follows;

On January…