Empresa Siderurgica, S. A. v. County of Merced

There was a cement plant in Merced County, California, which was sold to petitioner — a corporation of Colombia — for export to South America. An export license was obtained and a letter of credit in favor of the seller deposited here. Title passed' and possession was taken for the purchaser. A company, which was a common carrier, was employed to do the dismantling and packaging for shipment. As the dismantling proceeded, shipments were labeled with appellant’s name as consignee and delivered to a rail carrier.

Respondent, acting under a California statute,1 levied a personal property tax on…