SFPP, L.P. v. Arizona Department of Revenue

OPINION

GEMMILL, Judge.

¶ 1 Arizona Revised Statutes (“A.R.S.”) section 42-14204 (Supp.2003) prescribes the method of computing the valuation of pipelines for property tax purposes in Arizona. This appeal requires us to interpret the meaning of “original cost” as used in A.R.S. § 42-14204. The Arizona Tax Court decided that “original cost” in this statute means the original cost of placing the pipeline assets in service. The tax court rejected the position of the Arizona Department of Revenue (“Department”) that “original cost” means the original or acquisition cost to the current owner.…