GTE Sprint Communications Corp. v. County of Alameda

— Plaintiff, GTE Sprint Communications Corporation (Sprint), appeals from a judgment denying its complaint for property tax refunds (Rev. & Tax. Code, § 5148) for the years 1983 and 1984. In its complaint, as it did in its petitions for reassessment to the State Board of Equalization (the Board) below, Sprint contends that the Board’s appraisers unlawfully included the value of its nontaxable intangible assets in the unit appraisal of its California property. The Board responds that it was not directly taxing these intangible assets, but instead it was taxing the value of the tangible property as enhanced by the intangible values, in keeping with the well-established practice of ad valorem property taxation in this state. (See Roehm v. County of Orange (1948) 32 Cal.2d 280, 285 [ 196 P.2d 550 ]; ITT World Communications, Inc. v. City and County of San Francisco (1985) 37 Cal.3d 859, 863 [ 210 Cal.Rptr. 226 , 693 P.2d 811 ] [hereafter ITT #2].)

We hold that the Board’s valuation methodology, used to assess the full market value of Sprint’s tangible property, is invalid because it did not satisfactorily account for the value of Sprint’s intangible assets in appraising the…