City of Anaheim v. County of San Diego

Opinion

KAUFMAN, J.*

Plaintiffs City of Anaheim and City of Riverside (plaintiffs) appeal from a judgment which determined, for the purpose of fixing the tax lien assessment date, plaintiffs acquired their ownership interest in San Onofre Nuclear Generating Station (San Onofre Station) in 1980 rather than in 1977 as plaintiffs contended.

The Problem

The California Constitution, article XIII, section 11, subdivision (a), provides in pertinent part: “... Improvements owned by a local government that are outside its boundaries are taxable if they were taxable when acquired or were constructed by the…