Allstate Insurance v. County of Los Angeles

Opinion

FEINERMAN, P. J.

—We have before us two separate appeals which we have consolidated for decision. They present a single legal issue: Are cer tain office computer systems to be classified as realty or as personalty for purposes of property taxation? The distinction is crucial because in both cases the taxpayer is exempt from taxation of personal property.

In each of these cases the taxing authorities classified the property as fixtures to realty and assessed property tax accordingly. The taxpayers paid the taxes under protest and sought refunds via actions in the superior court. In 2d…