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CROCKER NATIONAL BANK v. CITY & CTY. OF SAN FRANCISCO

Docket No. S007833.

49 Cal.3d 881 (1989)

782 P.2d 278

264 Cal. Rptr. 139

CROCKER NATIONAL BANK, Plaintiff and Appellant, v. CITY AND COUNTY OF SAN FRANCISCO, Defendant and Appellant.

Supreme Court of California.

November 30, 1989.

Attorney(s) appearing for the Case

COUNSEL

Morrison & Foerster, William Alsup and Charles J. Moll III for Plaintiff and Appellant.

Philip M. Plant, Barbara L. Rosenfeld, Ehrman, Flavin, Devine & Baker, Sean Flavin, Kenneth A. Ehrman, R. Blair Reynolds, Stephens, Berg, Lasater, Schulman & Rogers and Mark G. Ancel as Amici Curiae on behalf of Plaintiff and Appellant.

Louise H. Renne, City Attorney, and John J. Doherty, Deputy City Attorney, for Defendant and Appellant.

Donald L. Clark, County Counsel (Santa Clara), and Thomas William Cain, Deputy County Counsel, as Amici Curiae on behalf of Defendant and Appellant.

OPINION

MOSK, J.

We granted review to address "[o]ne of the most controversial questions of classification" for purposes of taxation in the law of fixtures, that of electronic data processing equipment. (1 Ehrman & Flavin, Taxing Cal. Property (3d ed. 1988) § 3:04, p. 10; see Allstate Ins. Co. v. County of Los Angeles (1984) 161 Cal.App.3d 877 [

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