DEVINE, J.
The Learner Company, appellant, alleges in its complaint that it owned ships which were located in Alameda County on the first Monday in March, 1959, the tax lien date, and it submitted to the county assessor a valuation based on the price of scrap in or at South San Francisco, less cost of reducing the ships to scrap and cost of freight. The assessor used the cost of the property to the company, a higher valuation, and caused escape assessments to be made...
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