June 18, 1968

Dear Mr. __________:

This will confirm our telephone conversation of June 13, 1968.

In our view, Timber lands constitute “productive agricultural lands” as that phrase is used in subdivision (c) of Section 1227 of the California Financial Code. In modern usage, the word “agricultural” is a wide and comprehensive term, and statutes using it without qualification must be given an equally comprehensive meaning (Irvine Co. vs. California Employment Commission, 27 Cal. 2d 570, 576; Cannon vs. Industrial Accident Commission, 58 Cal. 2d 17, 21). According to Black’s Law Dictionary, the term “agricultural lands” is used merely to distinguish rural from urban or other properties. On the basis of these authorities, therefore, we believe that “agricultural lands” as used in subdivision (c) of Section 1227, should be construed to include timber lands. We note that subdivision (c) of Section 1227 requires that the agricultural lands be “productive”, but we think that, since timber lands produce trees for lumber and other purposes, timber lands must be considered as “productive”.

If we may be of further assistance to you, please feel free to call us.

Very truly yours,

Superintendent of Banks


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