Culligan Water Conditioning of Bellflower, Inc. v. State Board of Equalization

Opinion

SULLIVAN, J.

Defendant State Board of Equalization (Board) appeals from a judgment granting plaintiff Culligan Water Conditioning of Bellflower, Inc. recovery of certain use taxes paid under protest.

The case was tried by the court, sitting without a jury, upon an agreed statement of facts. In substance the pertinent facts are as follows: Plaintiff is in the business of conditioning water at the point of use. Hard water contains calcium and magnesium, and these “hardness” ions cause it to be unsuitable in the home for doing the laundry or for washing and bathing. Plaintiff “softens” the…