Trailer Train Co. v. State Board of Equalization

Respondent State Board of Equalization (Board) annually assesses and levies a property tax on appellant Trailer Train Company’s fleet of flatcars pursuant to the Private Railroad Car Tax Law (PRCTL). (Rev. & Tax. Code, § 11401.) In these consolidated appeals, Trailer Train challenges adverse trial court rulings that upheld the Board’s acts of levying an escape assessment for the 1976 tax year by disallowing a claim for functional obsolescence (case No. A021208) and refusing to use only the income capitalization method to value Trailer Train’s fleet of flatcars for the tax years 1977 through 1980 (case No. A027732) under the PRCTL. (§ 11201 et seq.)

In its appeal of the 1976 escape assessment, Trailer Train contends that: (1) the Board had no authority to levy the escape assessment; (2) the Board abused its discretion when applying an assessment different from that used in the original assessment; (3) substantial evidence did not support the Board’s findings; and (4) the trial court erred in granting the Board’s motion for summary judgment. In its appeal of the Board’s 1977-1980 assessments, Trailer Train contends that: (1) Board procedures violated due process; (2) it…