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Pier 67, Inc. v. King County, 89 Wash.2d 379, 573 P.2d 2

Facts

The case originated from a property tax dispute involving Pier 67, Inc. and the King County assessor regarding the valuation of leasehold interests and improvements on state-owned land. The taxpayer claimed that the assessments for the years 1963-72 were discriminatory, particularly noting that mortgage amortization deductions were allowed for similar properties in 1968 and 1969 but not for Pier 67. The trial court found discrimination for the years 1968 and 1969 but upheld the assessments for other years, leading to the appeal.

The trial court made the following findings and conclusions: (1) The leaseholds of Pier 67, Inc., the Olympic Hotel, and the University Properties, Inc., have similar characteristics making the comparison of valuations valid on the constitutional issues of discrimination and uniformity; (2) Pier 67, Inc., was unconstitutionally discriminated against for assessment years 1968 and 1969 based on the uncontested fact that mortgage payment deductions were allowed in those 2 years as to University Properties, Inc. while no similar deductions were granted when valuing appellant's leasehold and improvements.

Issue

Whether the property tax assessments for Pier 67, Inc. for the years 1963-72 violated constitutional provisions regarding uniformity and discrimination in taxation.

The primary issues are whether these valuations violate various provisions of the state and federal constitutions.

Rule

Tax assessments must be uniform and cannot discriminate against similar properties. The presumption of validity applies to property tax assessments, and the burden is on the taxpayer to prove discrimination.

Our constitution provides: 'All taxes shall be uniform upon the same class of property within the territorial limits of the authority levying the tax . . .' Const. art. 7, s 1 (amendment 14).

Analysis

The court analyzed the evidence presented regarding the assessment techniques used for Pier 67, Inc. compared to similar properties. It noted that the lack of preserved records for the years 1963-67 raised an inference of discriminatory practices. The court concluded that the assessments for 1968 and 1969 were discriminatory due to the allowance of deductions for other properties, and extended this finding to the years 1963-67 based on the established pattern of discrimination.

The trial court concluded the presumption of correct assessment must prevail for the years now at issue because the records which contained the valuation techniques utilized for the Olympic Hotel and University Properties, Inc. during these periods had not been preserved by the county, with the result that the appellant was unable to prove with absolute certainty that the Olympic Hotel and University Properties, Inc. had been allowed deductions which had been denied to the appellant.

Conclusion

The court reversed the trial court's decision regarding the assessments for the years 1963-67, finding them discriminatory and void, while affirming the findings for the years 1968-69. The case was remanded for further proceedings consistent with this opinion.

The judgment is reversed and remanded for further proceedings consistent with this opinion.

Who won?

Pier 67, Inc. prevailed in part, as the court found that the assessments for the years 1968-69 were discriminatory and extended this finding to the years 1963-67.

Appellant makes several assignments of error pertaining to the trial court's refusal to find it had been unconstitutionally discriminated against, not only during the years 1968 and 1969, but also 1963 through 1967, and 1970 through 1972.

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