In Crocker National Bank v. City & County of San Francisco (1989) 49 Cal.3d 881, defendant City of San Francisco had classified the bank's electronic data processing equipment as fixtures; the bank sought refunds for real property taxes it paid on the equipment, claiming it was in fact personal property. The trial judge rejected Crocker's claim, agreeing with the City's classification as fixtures. The Court of Appeal affirmed, reviewing the trial court's decision as the resolution of a fact question and governed by the substantial evidence test. The Supreme Court reversed: "The second issue to be addressed and resolved is the standard of review on appeal for a trial court's classification of a particular item of personal property as a fixture of the host real property for purposes of taxation. Our analysis is guided by the following general principles. "Questions of fact concern the establishment of historical or physical facts; their resolution is reviewed under the substantial-evidence test. Questions of law relate to the selection of a rule; their resolution is reviewed independently. Mixed questions of law and fact concern the application of the rule to the facts and the consequent determination whether the rule is satisfied. If the pertinent inquiry requires application of experience with human affairs, the question is predominantly factual and its determination is reviewed under the substantial-evidence test. If, by contrast, the inquiry requires a critical consideration, in a factual context, of legal principles and their underlying values, the question is predominantly legal and its determination is reviewed independently. "Thus, it is plain that on appeal a trial court's classification of a particular item as a fixture must be reviewed independently. The question of classification is mixed: it involves the application of the rule to the facts and the consequent determination whether the rule is satisfied. And the question is predominantly legal: the pertinent inquiry bears on the various policy considerations implicated in the solution of the problem of taxability, and therefore requires a critical consideration, in a factual context, of legal principles and their underlying values." (Crocker National Bank, supra, 49 Cal.3d at p. 888.) The California Supreme Court held the test for a fixture is "whether a reasonable person would consider the item in question to be a permanent part of the host real property, taking into account annexation, adaptation, and other objective manifestations of permanence." (Ibid.) Crocker also discussed the test for fixtures for purposes of conveyances such as mortgages, where the question is, "did the conveyance transfer interest in the items or not?" (Crocker, supra, 49 Cal.3d at p. 886.) The crucial factor is whether the mortgagor had an "'apparent'" intent to make the item "'a permanent accession to the freehold.'" (Ibid.) This factor focuses on "the objective 'intent' that would be inferred by a reasonable grantee or mortgagee," not the subjective intent of the annexor. (Ibid.) "'What does the grantee or mortgagee, as a reasonable man, think he is receiving under the conveyance'"? (Id. at pp. 886-887.) The Court also addressed the standard of review applicable to a trial court's ruling that bank property is a "fixture" or "personal property." Although a "mixed" question of fact and law, the court held the inquiry is "predominantly legal" subject to de novo review. (Crocker National Bank, supra, 49 Cal.3d at p. 888.) This standard, observed the court, was also "supported by the following consideration. Taxation must, of course, be uniform and the tax laws uniformly applied. (See Trabue Pittman Corp. v. County of L.A., supra, 29 Cal.2d at pp. 392-393, 397-398.) Uniformity depends on proper classification. And proper classification is furthered through the application of independent review." (Crocker National Bank, at pp. 888-889.)