Cochran

This is an appeal by the Assessor of Del Norte County after denial of his petition for a writ of mandamus in the Del Norte County Superior Court.

The case arises under the following circumstances.

On April 1 and 2, 1976, the Del Norte County Board of Supervisors (hereafter Board), sitting as a board of equalization, held hearings on the applications of Harold A., Jane S. and Prudence M. Miller, Joanne M. and Theodore Lilley, Achsah J. Graham, Darrell H. Schroeder, and Miller Redwood Co. (hereinafter applicants) for a reduction in the escape assessments made by the assessor on land to which variously they hold record title. The assessment was based upon the assessor’s conclusion that the lands owned by applicants should have been valued as separate tracts, and, as such, would have been both valued and taxed more highly. As appears in greater detail below, the Board disagreed, and its views were sustained by the trial court, leading to the present appeal.

I.

A perusal of the record reveals that the individual applicants are closely related: Harold and Jane Miller are husband and wife; Prudence MiHer, Achsah Graham and Joanne Lilley are their daughters; Theodore Lilley…