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WESTERN STATES PETROLEUM ASSN. v. BOARD OF EQUALIZATION

No. S200475.

57 Cal.4th 401 (2013)

159 Cal. Rptr. 3d 702

304 P.3d 188

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

Supreme Court of California.

August 5, 2013.

Attorney(s) appearing for the Case

Kamala D. Harris , Attorney General, David S. Chaney , Chief Assistant Attorney General, Alicia Fowler , Acting Chief Assistant 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.

John F. Krattli , County Counsel (Los Angeles) and Albert Ramseyer , Principal Deputy County Counsel, for Los Angeles County Office of the Assessor as Amicus Curiae on behalf of Defendant and Appellant.

Sharon L. Anderson , County Counsel (Contra Costa), Rebecca Hooley , Deputy County Counsel; Greenan, Peffer, Sallander & Lally, Kevin D. Lally , John P. Makin and Robin L. Thornton for Contra Costa County as Amicus Curiae on behalf of Defendant and Appellant.

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

OPINION

LIU, J.

This case presents the issue of how petroleum refinery property should be valued for purposes of taxation. In 1979, in response to the passage of Proposition 13 and related constitutional and statutory enactments, the state Board of Equalization (Board) enacted a rule for assessing the value of most industrial property. (See Cal. Code Regs., tit. 18, § 461.) Under that rule, the value of fixtures, including machinery and...

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