Senator, Inc. v. Ada County, Board of Equalization

EISMANN, Justice.

This is an appeal from a judgment of the district court affirming the tax assessment of a mobile home/manufactured home park. The taxpayer contends that to give major consideration to the actual and functional use of the park, the assessment must, as a matter of law, take into account the actual vacancy rate of the space rentals. We disagree and affirm the judgment of the district court.

I. FACTS AND PROCEDURAL HISTORY

The Senator, Inc., owns a mobile home/manufactured home park named “The Senator Retirement Community” (herein “Park”) located in Boise, Ada County, Idaho. The…