Southern Pacific Pipe Lines, Inc. v. State Board of Equalization

This appeal raises the question, to what extent may private oil company pipelines which run through more than one county be centrally assessed by the State Board of Equalization. For the reasons stated below, we affirm the trial court’s judgment, as modified, and hold that lands and rights-of-way through which such pipelines run must be locally assessed and taxed and that only the line itself and certain items necessary to its operation may be centrally assessed.

Facts and Procedural History

This tax refund action arises out of 15 consolidated lawsuits by various oil and pipeline companies against the State Board of Equalization and 19 counties. Four of those cases settled, leaving the following plaintiffs: Chevron, U.S.A., Inc.; Mobil Oil Corporation; Standard Gas Company; Standard Pipe Line Company; Shell Oil Company; Shell Western E&P, Inc.; Texaco Trading and Transportation, Inc.; Golden West Refining; and Union Oil Company of California (respondents).

In 1933, as part of the Riley-Stewart Tax Plan, the voters approved an amendment to California Constitution, article XIII, section 14, which provided for the central assessment and taxation by the SBE of certain…