The concept of realtors license "property" itself as a set of legal interests makes it plain that taxable interests in property must be defined as a specific type of intangible rather than by attempting to distinguish intangible interests from the ownership of physical objects. California has developed the concept of a taxable "possessory interest" in otherwise exempt property more fully than any other jurisdiction. An 1859 case established the taxability of a private mining claim upon federal property, even though the underlying property itself was explicitly exempt from tax under the terms of the act admitting California to the Union.  

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