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attorneystatuteappealtrialcorporation

appealtriallease

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Stewart Title & Trust of Tucson v. Pima County, 156 Ariz. 236, 751 P.2d 552

Facts

The case involves approximately 636 acres of land in Pima County, Arizona, which had been part of a continuous ranching operation for many years. The property was purchased by Nationwide Resources Corporation for investment purposes, with plans to develop it. Following the purchase, the Pima County Assessor reclassified the property as non-agricultural, leading to a dispute over its valuation and classification.

The property which is the subject of this appeal consists of approximately 636 acres of land, comprising all of Section 35, T15S, R14E, G & SRM, Pima County, Arizona.

Issue

The main legal issue was whether the property was correctly classified as agricultural or non-agricultural for tax purposes.

The question to be resolved is the proper classification of the property.

Rule

The court applied the Arizona property tax statutes, particularly A.R.S. § 42–141(A)(5), which requires that agricultural property be valued based on its current usage and prohibits consideration of urban or market influences in determining its value.

A.R.S. § 42–141(A)(5) requires the Department of Revenue (hereinafter “Department”) to: '[a]dopt standard appraisal methods and techniques for use by the department and county assessors in determining the valuation of property…'

Analysis

The court found that the trial court's determination that the property met the criteria for agricultural classification was supported by substantial evidence. The court emphasized that the historical use of the property for grazing and the ongoing ranching operation were significant factors in the classification, regardless of the owner's intent to develop the land.

The trial court found, with ample support in the record, that this property, in conjunction with other leased and fee-owned lands, has been part of a continuous ranching operation since the turn of the century.

Conclusion

The Court of Appeals affirmed the trial court's decision, holding that the property should be classified as agricultural and valued accordingly. The court also upheld the award of attorney fees to the taxpayers.

The trial court was correct in holding that it should be classified as agricultural and valued at $3,455 for 1985.

Who won?

The taxpayers prevailed in the case because the court found that the property was properly classified as agricultural, which was supported by the evidence presented.

The trial court found with ample support in the record that Section 35 and the grazing lease met the first six criteria in the Manual.

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Alexander Ranch, Inc. v. Central Appraisal Dist. of Erath County, 733 S.W.2d 303

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Lyon Metal Products, Inc. v. State Bd. of Equalization, 58 Cal.App.4th 906, 68 Cal.Rptr.2d 285, 97 Cal. Daily Op. Serv. 8221, 97 Daily Journal D.A.R. 13,284

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