Union Oil Co. v. State Board of Equalization

In this controversy as to the application of the California use tax to an extra-state sale and leaseback of two tankers we hold that an owner of property “uses” it under the tax statute when he leases it. The use of the lessor through the lease in California is a California use. The trial court’s finding that the purchaser at the date of the transaction anticipated that the lessee would use the vessels in California, and the subsequent actual use in California, render the transaction a purchase for use in this state. Hence the purchaser is liable for the tax upon the basis of the purchase…