Transamerica Development Co. v. Maricopa County

In Transamerica Development Co. v. Maricopa County, 107 Ariz. 396, 489 P.2d 33 (1971), the taxpayer disputed the assessor's valuation of its shopping center for the 1968 tax year. Id. at 397, 489 P.2d at 34. The assessor initially valued the land at $ 1,946,700 and the improvements at $ 917,760. Id. An appraiser later valued the land at $ 1,900,000 and the improvements at $ 412,500; the parties ultimately settled on a land value of $ 1,247,780 with the value of the improvements remaining at $ 917,760. Id. For the next tax year, 1969, the assessor maintained the land value but increased the improvement value to $ 1,258,385, resulting in an overall value of $ 2,506,165. Id. The taxpayer challenged this figure, hired the appraiser who conducted the previous valuation, and instructed the appraiser to value only the improvements. Id. The appraiser stated that this was a "most unusual" procedure to assume the validity of the $ 1,247,780 land value. Id. After surveying Arizona statutes on full cash value, the Arizona Supreme Court approved the government's valuation for the 1969 tax year. Id. at 398, 400, 489 P.2d at 35, 37. It noted that "authorities from jurisdictions with similar statutes overwhelmingly favor the proposition urged by the State in this case: that property valuation must be treated as a single entity." Id. at 398, 489 P.2d at 35. The Arizona Supreme Court explained: When questioning the reasonableness of property valuation for assessment purposes, property valuation must be considered one subject, not to be broken into separate components of land and improvements. The language of the Arizona statutes -- which discuss the valuation of Property, appellate review of Property valuation, etc. -- indicate that the concern of the Tax Board and the Superior Court should be the reasonableness of the total (land and improvements) valuation placed on the property, rather than the separate valuations. In other words, if the total valuation represents the full cash value of the property, it is immaterial for purposes of appeal that one part is overvalued and the other is undervalued. It is the total value that is the concern of the board and the court. Id. at 399, 489 P.2d at 36. Additionally, the court declined to recognize the previous year's valuation of the land as controlling: Neither are we concerned with the fact that the property was valued differently the previous year. While there may be some evidentiary value in previous valuation for the purposes of arriving at full cash value, the assessment must be considered on a year-to-year basis, and the previous year's valuation is not controlling. Id.