County of Orange v. Orange County Assessment Appeals Board No. 1

The County of Orange (County) appeals the judgment denying its petition for writ of mandamus seeking to set aside a decision of the Orange County Assessment Appeals Board No. 1 (Board), which adopted the position of taxpayer American Television and Communications Corporation (American) concerning the property tax on American’s cable television system. The County contends the Board erred as a matter of law by: (1) failing to consider the appropriate appraisal unit as a whole for valuation purposes; and (2) rejecting the comparable sales and income approaches in establishing the property’s value. We affirm.

The Board heard several days of testimony and made certain findings. The trial court relied on that testimony in ruling on the petition for writ of mandamus. We summarize the Board’s findings:

I

The County argues the Board erred as a matter of law by failing to consider all of American’s property as one appraisal unit for valuation purposes. In other words, the County claims the Board should not have separated the property into land and land improvements, fixtures, and personal property in determining the value of American’s property. We conclude the Board acted…