Chevron USA, Inc. v. County of Kern

This tax refund case concerns supplemental assessments of new construction consisting of the drilling, development, and completion of oil and gas wells, and related improvements and facilities, on various oil and gas properties operated by Chevron USA, Inc. (Chevron). In the trial court, Chevron and its parent corporation, Chevron Corporation (Corp), challenged the method by which the Kern County Assessor (assessor) and Kern County Assessment Appeals Board (Board) valued the wells as new construction during three tax years. (Rev. & Tax. Code, § 5140 et seq.) The trial court found that the Board used the wrong valuation method and remanded the matter for the Board to determine the propriety of issuing supplemental assessments on the wells. The trial court further rejected Chevron’s assertion that certain wells were exempt from supplemental assessment.

The County of Kern (Kern) appeals, arguing (1) Chevron does not have standing to bring a tax refund action, and (2) the Board did not act arbitrarily, abuse its discretion, or violate the law when it approved the valuation method the assessor used. Chevron has cross-appealed, arguing certain wells are exempt from…