Guild Wineries & Distilleries v. County of Fresno

In August 1971, appellant petitioned the Board of Supervisors of Fresno County, sitting as a county board of equalization, for a reduction of the assessment made by the county assessor for the tax year 1971-1972 on appellant’s winery and distillery plant in Fresno. Appellant did not challenge the value placed by the assessor upon the land or inventory but contended that the assessed value of the improvements was excessive; using the replacement cost approach to appraise the improvements, the assessor valued the plant at $3,023,340.

At the hearing before the board, appellant presented evidence to show that appellant is a large agricultural cooperative engaged in the crushing and selling of wine products and that on February 26, 1971, three days before the lien date, it purchased the Roma Wine Division of Schenley Industries for the total purchase price of $12,807,137; the purchase encompassed the winery plant in Fresno, a winery in Kingsburg, a winery in Delano, vineyards in Tulare and Kern Counties, brands and trademarks, and supplies and inventories. Then, using data prepared by its accountants, appellant attempted to prove that the value of the Fresno plant was…