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statuteleasecorporationappellant
statuteleasecorporationappellant

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Pacific Intermountain Exp. Co. v. State Tax Commission, 108 Utah 478, 161 P.2d 359

Facts

Pacific Intermountain Express Company leased certain truck-tractors and semitrailers from the Defense Corporation of the United States for the transportation of military supplies. The lease stipulated that the Defense Corporation retained ownership and control over the equipment, allowing it to cancel the lease under specific conditions. The company argued that since the trucks were owned by the United States government, they should be exempt from the registration fee as per Utah law.

The complaint alleges among other things that on April 19, 1945, the Defense Corporation, by a written lease, a copy of which is attached to the complaint, leased to appellant certain truck-tractors and semitrailers for use by appellant on the highway subject to certain control of the Defense Corporation and mainly for the transportation of military supplies for ultimate use by the government.

Issue

Is Pacific Intermountain Express Company immune from paying the registration fee for the leased trucks under Utah law, given that the trucks are owned by the United States government?

The question here to be determined is: Are these trucks ‘owned’ by the United States Government under the meaning of this term as used in this statute?

Rule

Under Section 57-3a-138, U.C.A.1943, no fees shall be charged for the registration of trucks owned by the United States government.

‘(a) No fees shall be charged for the registration of * * * trucks owned by the United States government, * * * but all such vehicles shall be registered and given a number, * * *.’

Analysis

The court analyzed whether the trucks were 'owned' by the United States government as defined in the relevant statute. It concluded that the Defense Corporation, while holding legal title, was acting on behalf of the United States, thus making the trucks effectively owned by the government. The court determined that the appellant's lease did not grant it the right of purchase as defined in the statute, which influenced the interpretation of ownership.

If the term ‘owned’ is to be given its ordinary meaning, then these trucks are clearly owned by the United States Government.

Conclusion

The court reversed the District Court's dismissal and remanded the case, directing that the appellant is immune from the registration fee for the trucks leased from the Defense Corporation.

The case is reversed and remanded to the District Court with directions to proceed in accordance with the views herein expressed.

Who won?

Pacific Intermountain Express Company prevailed because the court found that the trucks were owned by the United States government, thus entitling the company to immunity from the registration fee.

Appellant urges that under this lease these truck-tractors and semitrailers are owned by the United States Government and therefore under Section 57-3a-138, U.C.A.1943, appellant is immune from paying the registration fee.

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