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WESTERN STATES PETROLEUM ASSN. v. BOARD OF EQUALIZATION

No. B225932.

202 Cal.App.4th 1092 (2012)

WESTERN STATES PETROLEUM ASSOCIATION, Plaintiff and Respondent, v. BOARD OF EQUALIZATION, Defendant and Appellant.

Court of Appeals of California, Second District, Division Eight.

January 19, 2012.

Attorney(s) appearing for the Case

Kamala D. Harris, Attorney General, Paul D. Gifford, Assistant Attorney General, Felix E. Leatherwood, W. Dean Freeman and Brian D. Wesley, Deputy Attorneys General, for Defendant and Appellant.

Cahill Davis & O'Neall, C. Stephen Davis, Cris K. O'Neall and Andrew W. Bodeau for Plaintiff and Respondent.

OPINION

BIGELOW, P. J.—

For more than 25 years, the state Board of Equalization (SBE) directed county assessors to assess the value of the "real property" at petroleum refineries by applying valuation formulas generally applicable to all industrial and manufacturing properties. (See Cal. Code Regs., tit. 18, § 461.) Then, responding to entreaties from a number of county-level government officials, SBE concluded that it had become...

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