Calpine Construction Finance Co. v. Arizona Department of Revenue
In Calpine Construction Finance Co. v. Arizona Department of Revenue, 221 Ariz. 244, 211 P.3d 1228 (App. 2009), the disputed question was whether the taxpayer or an Indian tribe owned improvements located on tribal land. 221 Ariz. at 248,15, 211 P.3d at 1232.
Ownership is not an issue in the case at bar.
The statute at issue in Stewart Title expressly directed that property be valued based on "current usage," which was defined as "the use to which property is put at the time of valuation." 156 Ariz. at 240, 751 P.2d at 556.
Because the taxpayer's property was then leased for grazing, it was properly classified as agricultural, notwithstanding the owner's admitted goal of selling it for development purposes. Id.