Sprint Telephony v. State Board of Equalization

I.

FACTUAL AND PROCEDURAL

BACKGROUND

A. The Statutory Framework for State-assessed Property. California property owners who dispute the government’s assessment of their property for tax purposes may generally request to have the property reassessed at a lower valuation and request a refund of paid taxes that were based on an excess valuation. They must make both requests before bringing a judicial tax-refund action. In many situations, the same government body considers these two requests and can grant or deny the relief sought. And in many situations, property owners may submit the two requests either together or separately. When taxpayers of county-assessed property seek reassessments and refunds, for example, they may either state in their applications for reassessment that they want a refund or they may file a separate claim for refund with the county. (§ 5097, subds. (b) & (c); see also §§ 1603-1604.) This case involves a unique assessment-and-refund procedure applicable to certain entities, including telephone companies such as Sprint, that typically hold property in multiple counties.2 The California Constitution requires the Board annually to assess telephone companies’…