Bank of America National Trust & Savings Ass'n v. County of Los Angeles

Plaintiff seeks a refund of taxes paid under protest to defendants, the County of Los Angeles and certain cities for which it collects taxes. The taxes in question were levied on several electronic computer systems installed in various buildings owned by plaintiff. The trial court held the systems to be fixtures and taxable as improvements to real property. Plaintiff appeals from such judgment.

The sole issue before the trial court was the taxability of such property as fixtures. If such equipment constitutes personal property, defendants admittedly have no power to tax it. (Cal. Const., art.…