ASI

American Sheds, Inc. (ASI), and its parent corporation Browning-Ferris Services, Inc. (BFI; collectively plaintiffs), appeal from a judgment after court trial in an action for refund of real property taxes paid to defendant County of Los Angeles (county). The taxes were levied on a 302-acre landfill property in the cities of Azusa and Irwindale (the property), which ASI acquired in 1987 together with ownership of the corporation that operates the landfill, Azusa Land Reclamation Company (ALR).

Plaintiffs’ fundamental contention is that in assessing the market value of the property, the county’s assessment appeals board (board) improperly included the value of certain related intangibles of the landfill business, namely, its operating permits and “business enterprise” value. Plaintiffs also contend that certain factors of the board’s value determination are not supported by substantial evidence. We conclude that the judgment approving the board’s method of valuation must be affirmed.

Facts

In 1987, ASI acquired the property, and the stock of ALR, for a consideration of $60.3 million, together with agreed additional payments to the seller of 10 percent of the “gate…