S. & G. Gump Co. v. City & County of San Francisco

In 1936, the appellant paid under protest taxes upon personal property which was held by it on consignment and subsequently sued to recover the amount of such payment. There is no dispute concerning the facts and the judgment in favor of the respondent is based upon a construction of the applicable statutes.

At the time the assessment was made, the appellant was a dealer in art goods and merchandise and had in its possession certain goods entrusted to it for sale. It filed with the assessor of the City and County of San Francisco a statement or declaration of taxable personal property owned by…