Sacramento Mun. Utility Dist. v. County of Solano

Opinion

PUGLIA, P. J.

Revenue and Taxation Code section 7284 (section 7284) authorizes the board of supervisors of any county to “license, for revenue and regulation, and fix the license tax upon, every kind of lawful business transacted in the unincorporated area of the county . . . .” In this appeal we conclude that the performance of a governmental function by a public agency does not constitute the transaction of business within the meaning of section 7284 so as to authorize the licensing and taxation of that activity.

I

Sacramento Municipal Utility District (SMUD) is established under the…