Crystal Point Joint Venture v. Arizona Department of Revenue
In Crystal Point Joint Venture v. Arizona Department of Revenue, 188 Ariz. 96, 932 P.2d 1367 (App. 1997), the Court did no more than apply section 33-1204(B) to one of the controversies that it was plainly designed to resolve--a dispute about the circumstances under which a group of condominium units, whose ownership the declarant retained, could be valued, assessed, and taxed as a single parcel of real property.
The Court held that, under A.R.S. section 33-1204, "if even one unit in the complex is owned by someone other than the declarant, every unit must be treated as a separate parcel of real estate and separately valued, assessed, and taxed." Crystal Point Joint Venture, 188 Ariz. at 101, 932 P.2d at 1372.
But if a declarant owns every unit, the "units that comprise the complex are to be valued, assessed, and taxed as a single parcel." Id.
Based on this analysis, the Court rejected the taxpayer's proposed "bulk sales" valuation method, representing "what one willing buyer would have paid for all the units." Id. at 99, 932 P.2d at 1370.