Ventura County hearing splits over how to value Target27s store fixtures; assessor defends 12-year life, agent seeks steep reductions

The Ventura County Assessment Appeals Board spent most of a multi-hour hearing wrestling with whether Target Corporation27s store fixtures should be depreciated on a 12-year or a 9-year economic life and whether additional external obsolescence reductions are warranted for lien years 2019 through 2023.

Todd Court, an appraiser with the Ventura County Assessor27s Office, opened the assessor27s presentation by describing an audit of Target27s fixed-asset listings and invoices and walking the board through the assessor27s use of the cost approach. Court said the office relied on the State Board of Equalization (BOE) and California Assessors Association (CEA) indexes and percent-good tables and concluded the taxpayer had capitalized costs correctly: "It's our opinion that the taxpayer capitalized the property correctly," Court told the board.

Court and Amanda Calhoun, the assessor27s auditor-appraiser, said the assessor did not use an income or sales-comparison approach because those methods do not reliably apply to mass-assessed retail fixtures. Instead the assessor starts with recorded historical cost, indexes it to the lien date and then applies BOE percent-good depreciation and a reverse-trending sampling method to remove disposals and credit documented refurbishments.

The assessor also relied on CEA/BOE life studies for retail and…