In Easton v. County of Alameda (1937) 9 Cal.2d 301, a real property owner brought a refund action to recover excess property taxes paid by its tenant pursuant to a lease agreement. The property owner argued it had standing to proceed in a refund action because it was the party assessed and thus the one legally responsible for paying the tax. The court disagreed. Relying on statutory language in former Political Code section 3804 prohibiting recovery in a refund action when the action is "brought by an assignee of the person paying the tax or by any person other than the person who has paid the tax,"6 the court concluded only the party who paid the tax could obtain a refund. The court explained the language "shows a legislative intention to allow tax refunds only to those persons who pay the taxes claimed to have been erroneously assessed. The statute operates to benefit 'all persons who pay taxes they are not legally bound to pay' but does not allow a recovery by a property owner whose taxes have been paid by someone else under a contract to do so. In that case the property owner has parted with nothing and he has no valid claim for a refund." (Easton, at pp. 303-304.) Like section 30407, former Political Code section 3804 provided, "'In no case shall any judgment be rendered in favor of plaintiff in any action brought for the enforcement or allowance of any rights or claims under this section ... if the said action be brought by an assignee of the person paying said tax, or by any person other than the person who has paid the tax ... .'" (Easton, supra, 9 Cal.2d at pp. 302-303.) In 1872, Political Code section 3804 (the predecessor statute to Rev. & Tax. Code, 5140) was enacted providing, "Any taxes, per centum, and costs erroneously or illegally collected, may by order of the Board of Supervisors, be refunded by the County Treasurer." In 1889, Political Code section 3804 was amended to permit a refund "to the person entitled to the same." (Stats. 1889, ch. 236, 1, p. 347.) In 1913, the section was again amended to restrict tax refunds "to the person paying the same or his guardian, or in case of his death, to his executor or administrator," and added the provision that "in no case shall any judgment be rendered in favor of plaintiff in any action ... brought by an assignee of the person paying said tax, or by any person other than the person who has paid said tax, or his representative." (Stats. 1913, ch. 145, 1, p. 229.) Finally, in 1919, the section was amended to require a verified claim "by the person who has paid said tax." (Stats. 1919, ch. 274, 1, p. 450.) Easton held that the statute "operates to benefit 'all persons who pay taxes they are not legally bound to pay' but does not allow a recovery by a property owner whose taxes have been paid by someone else under a contract to do so. In that case the property owner has parted with nothing and he has no valid claim for a refund." (Easton, at pp. 303-304.)