Walmart

BACKGROUND

A The California Constitution provides that, unless exempt, “[a]ll property is taxable and shall be assessed at . . . fair market value.” (Cal. Const., art. XIII, § 1, subd. (a).) The county assessor bears the duty to determine the full value of real property for taxation purposes. (Rev. & Tax. Code, § 401.)2 “Full value” and synonymous terms such as “fair market value” “mean the price at which the unencumbered or unrestricted fee simple interest in the real property (subject to any legally enforceable governmental restrictions) would transfer for cash or its equivalent . . . .” (Cal. Code Regs., tit. 18, § 2, subd. (a).) After its properties were assessed, Walmart paid the property taxes and filed applications for refund with the Board. The applications alleged the assessor incorrectly determined the fair market values of the properties. (§ 1603, subd. (a).) The Board conducted a hearing on the applications, considered oral testimony and documentary evidence, and sustained the assessor’s recommended values with written findings.3 (§ 1611.5.) Walmart filed a complaint for refund of property taxes. (§ 5140.) The complaint alleged the properties were incorrectly assessed…