
Arizona SALT Newsletter Vol. 37
In the recent A & P Ranch case, the Arizona Court of Appeals held that Arizona's property taxation scheme requires "permanent crops," such as pecan trees and grape vines, to be valued as part of the land using an income approach mandated by Arizona law. The court reached this decision even though the Arizona Department of Revenue's ("ADOR's") Agricultural Property Manual instructed county assessors to value permanent crops separately for over 40 years. The court recognized that it must "decide all questions of law without deference to any determination that is made by [ADOR]," and disregarded the notion that "the legislature is aware of all of the regulations adopted by the numerous state regulatory agencies and tacitly approves them if it does not take contrary action."
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