Mercury Casualty Co. v. State Board of Equalization

Opinion

LUI, J.

Appellant Mercury Casualty Company (Mercury) appeals from the judgment entered below in favor of the respondent State Board of Equalization (Board) following a trial by the court based on stipulated facts and written and oral arguments of counsel. This appeal concerns the precise question of whether Mercury exhausted its administrative remedies under the claims statutes so as to enable it to recover taxes erroneously collected by the Board for the years 1971 through 1973, 1977 and 1978 which it paid under protest. We reject Mercury’s contentions and affirm the judgment.

Factual…