In Jackson & Perkins Co. v. Stanislaus County Board of Supervisors (1959) 168 Cal.App.2d 559, plaintiff corporation grew rose bushes and other plants for sale as nursery articles. The ground was leveled, subsoiled, and planted to rose cuttings taken from wild stock. The developing plants were irrigated and weeded, and then budded to the desired types of roses. Testimony established that it takes one to two years to complete the plants to the point where they are salable; one year for plants intended to be used for their cut flowers and two years for plants intended for open air planting. It was also shown that the plants became commercially valueless after these time periods, that they are not grown for the profit from the products of the plant, and that they require maintenance with farm-type procedures. ( Id., at pp. 559-560.) The appellate court held that both the one- and two-year rose bushes raised by plaintiff were not entitled to the "growing crop" exemption. Relying upon Story, the court initially found that the nursery stock had the characteristics of personalty taxed as stock in trade. ( Id., at p. 563.) Moreover, it also relied upon the Washington case of Miethke v. Pierce County, 173 Wash. 381, which ruled that nursery stock sold for transplanting by customers did not constitute a growing crop. ( Jackson & Perkins Co. v. Stanislaus County Board of Supervisors, supra, 168 Cal.App.2d at pp. 563-564.) Finally, the court noted that its characterization accorded with the administrative interpretation given to nursery stock since 1948. ( Id., at p. 564.)