County of Los Angeles v. County of Los Angeles Assessment Appeals Board No. 1

The County of Los Angeles (County) seeks reversal of a judgment which denied its petition for writ of mandate against the County’s assessment appeals board (Board) and awarded possessory interest tax refunds to car rental companies that operate at the three major airports within the County. The Board and the trial court rejected the County’s contention that the rent-a-cars’ possessory interests extend to the use of each airport generally, not simply the areas the companies occupy (principally service counters), and also disapproved the County’s method of valuing the interests, by capitalizing concession fees which were based on and included enterprise income. We conclude that the trial court correctly resolved these issues, which to some extent had already been conclusively determined by another superior court judgment in 1986. The judgment consequently will be affirmed.

Facts

This case concerns ad valorem property tax assessments of possessory interests of four car rental companies (Dollar Rent A Car Systems, Inc. (Dollar), Grand Rent A Car Corporation (Avis), The Hertz Corporation (Hertz), and National Car Rental System, Inc. (National), hereafter collectively the…