REGAN, J.
Plaintiff was the record owner of reserved oil, gas and other hydrocarbon rights which had been assessed by the assessor of Tehama County. It paid the taxes under protest and commenced this action to recover the sums so paid, and appeals from the judgment for defendant.
By stipulation of counsel, this cause was submitted to the trial court on the record, which includes the transcript of the proceedings before the Board of Supervisors of Tehama County...
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