Property Valuation Methods In Arizona Tax Law

In Arizona, property is valued based on its "full cash value," unless otherwise prescribed by statute. See A.R.S. 42-13051(B) (Supp. 2006). Although the state legislature has defined full cash value as being "synonymous" with market value and has defined market value as the "estimate of value that is derived annually by using standard appraisal methods and techniques," A.R.S. 42-11001(6) (Supp. 2006), it has also specified that in applying standard appraisal methods and techniques, "current usage shall be included in the formula for reaching a determination of full cash value." A.R.S. 42-11054(C)(1) (Supp. 2006). The legislature has also directed that "if the methods and techniques prescribe using market data as an indication of market value, the price paid for future anticipated property increments shall be excluded." A.R.S. 42-11054(D). This language, the Arizona Supreme Court has explained, constitutes "another way of saying that market data valuation for property tax purposes must be limited to present usage." Golder v. Dep't of Revenue, 123 Ariz. 260, 265, 599 P.2d 216, 221 (1979). In Golder, the court illustrated the difference between valuing property based on current usage and highest and best use: If land is being used for agricultural purposes in the middle of urban growth, the statute in question requires that it be appraised on the basis of current usage. If a market data approach were used to appraise the land, the value of surrounding land would reflect the value for future housing or commercial use. This anticipated or future use may not be used in fixing a value for the land being used as a farm. The difference between market value and the value of the land for agricultural purposes represents that portion of the price which buyers would have to pay for 'future anticipated property value increments.' Since the statute requires that 'current use' be considered in assessing the property, the agricultural user is taxed only to the extent that the land has value for agricultural purposes. the excess is excluded as the statute requires. Id. at 265-66, 599 P.2d 221-22.