Auerbach

INTRODUCTION

Real party in interest TWC Aviation, Inc. (TWC Aviation), leased three aircraft from real parties in interest AML Leasing LLC (AML) and DWAL LLC (DWAL) 1 to operate as on-demand air taxis. Petitioner and respondent Rick Auerbach, in his capacity as the Los Angeles County Assessor (Assessor), levied, i.e., enrolled, 2 property tax assessments on the aircraft. TWC applied for changed assessments before the Los Angeles County Assessment Appeals Board No. 2 (Appeals Board). TWC contended, inter alia, that the Assessor’s proposed apportionment formula—to account for the time during the tax year that the aircraft were in Nevada—was arbitrary, resulting in a combined valuation by California and Nevada that exceeded 100 percent of the value of the aircraft, and that the Appeals Board should instead adopt the formula used by Nevada. The Appeals Board agreed with TWC and adjusted the assessments accordingly.

The Assessor filed a petition for a writ of administrative mandamus in the trial court seeking to overturn the findings of the Appeals Board. The trial *1418 court denied the petition as to another issue, but granted it as to the apportionment issue. The Assessor…