MARCHIANO, P.J.
Plaintiff J.W. Silveira seeks refunds of possessory interest taxes paid in several years to defendant County of Alameda on his month-to-month tenancy with the City of Oakland. He contests the years-long anticipated terms of possession used to calculate the value of his possessory interest, arguing that, under the decision in American Airlines, Inc. v. County of Los Angeles (1976)
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