Texaco Producing, Inc. v. County of Kern

This appeal concerns the assessment of oil producing property owned and operated by appellant, Texaco Producing, Inc. (Texaco), for the years 1984, 1985 and 1986. In an attempt to overcome the presumption that ad valorem property tax assessments are correct, Texaco challenges the legality of appraisal methods used by the Kern County Assessor (Assessor). Texaco further argues the appraised values are not supported by substantial evidence. However, Texaco has failed to meet its burden of demonstrating error. Thus, the assessments must be upheld.

Statement of the Case

In February 1984, Getty Oil Company (Getty) was merged into Texaco through Texaco’s purchase of Getty’s stock. Texaco’s acquisition of Getty triggered a reassessment of the real property interests previously owned by Getty as a change of ownership under Proposition 13. (Cal. Const., art. XIII A; Rev. & Tax. Code, § 64. ) This property transfer included fee holdings and leasehold interests in over 5,830 acres located in an oil producing area known as the Kern River Oilfield (Kern River).

The Assessor reappraised this Kern River property as of the March 1, 1984, lien date to establish a new base-year value.…