The County of Alameda (County) and City of Oakland (City) appeal from a judgment concluding that the taxpayer, respondent, Sea-Land Service, Inc. (Sea-Land), did not acquire a taxable possessory interest under its "Preferential Assignment Agreement," and directing the refund of 1967-68 personal property taxes levied and collected by the City for the County. As we have concluded that the agreement created a taxable...
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