Union Pacific Railroad v. State Board of Equalization

Opinion

LOW, P. J.

In this case we review the methods used by the State Board of Equalization (the Board) to assess railroad operating assets. We conclude, as did the superior court, that the Board’s “composite life” model cannot legally be applied to railroad operating property. We also hold, however, that the superior court erred in finding illegal certain Board techniques for estimating current railroad income.

Several railroad companies (the Railroads) 1 brought these consolidated actions for refund of property taxes paid in 1978, 1979, and 1980. (Cal. Const., art. XIII, § 32; Rev. & Tax.…