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HomeMy WebLinkAbout20072217.tiff RESOLUTION RE: THE BOARD OF EQUALIZATION, 2007, WELD COUNTY, COLORADO - DENY PETITIONER'S APPEAL AND AFFIRM ASSESSOR'S VALUE PETITION OF: VALERO DIAMOND METRO INC#4109 AD VALOREM TAX DEPT PO BOX 690110 SAN ANTONIO, TX 78269-0110 DESCRIPTION OF PROPERTY: ACCOUNT#: P0012682 PARCEL#: 147106132016-FTL 15145 BLK 21 TWOMBLYS 101 DENVER AV FORT LUPTON 00000 WHEREAS, the Board of County Commissioners of Weld County,Colorado,convened as the Board of Equalization for the purpose of adjusting, equalizing, raising or lowering the assessment and valuation of real and personal property within Weld County,fixed and made by the County Assessor for the year 2007, and WHEREAS, said petition has been heard before the County Assessor and due Notice of Determination thereon has been given to the taxpayer(s), and WHEREAS, the taxpayer(s) presented a petition of appeal of the County Assessor's valuation for the year 2007,claiming that the property described in such petition was assessed too high, as more specifically stated in said petition, and WHEREAS, said petitioner not being present or represented, and WHEREAS,the Board has made its findings on the evidence,testimony and remonstrances and is now fully informed. NOW,THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County,acting as the Weld County Board of Equalization,that the evidence presented at the hearing clearly supported the value placed upon the Petitioner's property,after review by the Weld County Assessor. Such evidence indicated the value was reasonable,equitable,and derived according to the methodologies,percentages,figures and formulas dictated to the Weld County Assessor by law. The assessment and valuation of the Weld County Assessor shall be, and hereby is, affirmed as follows: ACTUAL VALUE AS DETERMINED BY ASSESSOR Land $ 0 Improvements OR Personal Property 223,163 TOTAL $ 223,163 2007-2217 at; ,9s, e4 i9e Ee AS 067 RE: BOE -VALERO DIAMOND METRO INC #4109 PAGE 2 BE IT FURTHER RESOLVED that a denial of a petition, in whole or in part, by the Board of Equalization may be appealed by selecting one of the following three options;however,said appeal must be filed within 30 days of the denial: 1. Board of Assessment Appeals: You have the right to appeal the County Board of Equalization's(CBOE's)decision to the Board of Assessment Appeals(BAA). Such hearing is the final hearing at which testimony, exhibits, or any other evidence may be introduced. If the decision of the BAA is further appealed to the Court of Appeals,only the record created at the BAA hearing shall be the basis for the Court's decision. No new evidence can be introduced at the Court of Appeals. (Section 39-8-108(10), C.R.S.) Appeals to the BAA must be made on forms furnished by the BAA, and such appeals should be mailed or delivered within thirty(30)days of denial by the CBOE to: Board of Assessment Appeals 1313 Sherman Street, Room 315 Denver, CO 80203 Phone: 303-866-5880 Fees: A taxpayer representing himself is not charged for the first two appeals to the Board of Assessment Appeals; however,a taxpayer being represented by an agent or an attorney must submit a fee of$101.25 per appeal. OR 2. District Court: You have the right to appeal the CBOE's decision to the District Courtof the county wherein your property is located. New testimony,exhibits or any other evidence may be introduced at the District Court hearing. For filing requirements, please contact your attorney or the Clerk of the District Court. Further appeal of the District Court's decision is made to the Court of Appeals fora review of the record. (Section 39-8-108(1), C.R.S.) OR 3. Binding Arbitration: You have the right to submit your case to arbitration. If you choose this option the arbitrator's decision is final and your right to appeal your current valuation ends. (Section 39-8-108.5, C.R.S.) Selecting the Arbitrator: In order to pursue arbitration, you must notify the CBOE of your intent. You and the CBOE select an arbitrator from the official list of qualified people. If you cannot agree on an arbitrator,the District Court of the county in which the property is located will make the selection. 2007-2217 AS0067 RE: BOE - VALERO DIAMOND METRO INC#4109 PAGE 3 Arbitration Hearing Procedure: Arbitration hearings are held within sixty days from the date the arbitrator is selected. Both you and the CBOE are entitled to participate. The hearings are informal. The arbitrator has the authority to issue subpoenas for witnesses, books, records,documents and other evidence. He also has the power to administer oaths, and all questions of law and fact shall be determined by him. The arbitration hearing may be confidential and closed to the public,upon mutual agreement. The arbitrator's written decision must be delivered to both parties personally or by registered mail within ten (10) days of the hearing. Such decision is final and not subject to review. Fees and Expenses: The arbitrator's fees and expenses are agreed upon by you and the CBOE. In the case of residential real property, such fees and expenses cannot exceed$150.00 per case. The arbitrator's fees and expenses, not including counsel fees, are to be paid as provided in the decision. The above and foregoing Resolution was,on motion duly made and seconded,adopted by the following vote on the 2nd day of August, A.D., 2007. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: / / t XCUSED 0i,,•— '[11avid E. Long, Chair Weld County Clerk to the' •. :, ► , /�� i' "'" liter O��I `.•, William H. Jerk Tem BY: d/LI/t Deputy Clerk o the Board William F. Garcia APPROVED AS TO FORM: EXCUSED Robert D. Masden A slant unty Attornei/ Douglas demache Date of signature: 1/9o7Ce2 2007-2217 AS0067 WELD COUNTY CHRISTOPHER WOODRUFF COUNTY ASSESSOR BRENDA DONES, DEPUTY ASSESSOR VALUATION REPORT OF PERSONAL PROPERTY FOR County Board of Equalization VALERO DIAMOND METRO INC #4109 PETITIONER Vs. WELD COUNTY ASSESSOR'S OFFICE RESPONDENT Schedule Number: P0012682 Log Number: 4241 Date: August 2, 2007 Time: 4:40pm Board: BOARD PREPARED BY APPRAISERS NAME Raelene Anderson 7/25/07 Signature Date ASSESSOR'S OFFICE STAFF APPRAISER CBOE_PP_010998 Page 1 COST APPROACH Location of the subject property is: Street Address 101 DENVER AV City FORT LUPTON Pursuant to Colorado Revised Statutes the cost approach of Personal Property listed on the above mentioned property is attached, along with a copy of the declaration and/or correspondence from the petitioner. NARRATIVE The value on this account was derived from an asset listing supplied by the petitioner with their 2005 Personal Property Declaration. The actual value of$223,163 was determined by listing all of the assets reported, the year purchased and their cost, then applying the appropriate tables and factors as mandated by the State Department of Property Taxation. COST APPROACH VALUE $223,163 CBOE_PP_010998 Page 2 MARKET APPROACH Pursuant to Colorado Revised Statute the Assessor has considered the Market Approach to value on Personal Property. Due to the insufficient information for the market of personal property, the Weld County Assessor has not utilized the Market Approach. INCOME APPROACH Pursuant to Colorado Revised Statute the Assessor has considered the Income Approach to value on Personal Property. Due to the insufficient information for the income on Personal Property, the Weld County Assessor has not utilized the Income Approach. CBOE_PP010998 Page 3 CONCLUSION The subject property has been classified as Personal Property for property tax purposes. Personal Property values shall be determined by appropriate consideration of the Cost Approach, Market Approach, and Income Approach to value. {39-1-103)(5)(a) CRS} The Assessor has considered the three approaches to value for the subject property. It is the petitioner's responsibility to provide sufficient evidence to substantiate that the Assessor's value is incorrect. After consideration of the three approaches, it is the Weld County Assessor's request that the value of $223,163 be affirmed for the tax year 2007. ASSESSOR'S VALUE $223,163 CSOE_PP_010998 Page 4 CONFIDENTIAL ASSESSMENT DATE MAii TO PERSONAL PROPERTY JANUARY 1,2007 WIRD COUNTY ASSESSOR DECLARATION SCHEDULE 1400 N.I?AVE GRPDEY.CO POI (Calaitl Da DUE DATE APRIL 15,2007 pump pa THRIU Pa MA 3044433 2007 Heat assmaansamadisam . Retain This Can it'.`\� RECEIVED AMESSOR'S USEOeaY >PLEASE READ INSTRUCTENE ON N C01SFEIFD IMMO RETIRED=COT LATE FILING FEE YES() NO() PIN NUMBER TA CODE BA CODE PARCEL NUMBER P0012112 0160 28045 147106132016 263400001 A.NAME MID MAILING ADORES*YeMe.btavi—A r nI ,„A,Y.IIe,e. RECEIVED� a AD VALOR TAX DEPT f 41O1 ''�j�� PO BOX 6901.10 JAN 2 2 2007 PREY 'S NAME a ADDRESS SAN ANTONIO, TX 70269-0110 • APR 0 7 7007 ,nLn3_._... eM31.d 1*1W( lS NAME AND PHYSICAL LOCATION of AD Sono:r,7 G;DE'JFTENI SHOW CHANGES OF PHYSICAL LOCATION: PERSONAL PROPERTY AS OF JANUARY 1,7007 ----- WELD COUNTY ASSESSOR FTL 15145 DLL 21 T6OIOLYS SITOS: 101 DENVER.AV-r0t Lbriowt o0000p�y�'j E�. Y'-r'' '�F�A--t. - t AiMcheek is rent_ iffa•744 Rosiness Orris: Pates a Service?midst D NOT CURRENT OWNER.n you an not"is wrens loins area,clock hen and provide the nova and Was of Sc new ewer: Dee SON: O NEW . a ass Me a Mm, Personal popsy.the Be Fns pen et Section D ad nit Aen(s)if needed. In ecmd�as wilt 39.3-119.5,CAB.,yon we set required is the darn:eia„ the eW aoad vie(deplacire Mee)d or Yu.Haw s. as MD a re arse a e wit,the al read are of �uapaass the y per�ryatt'� B'b[87DVG Y ease year urea,tan" netll wiether a eayour doe penal popw�y precis*euwesh A�4 plse coact wily weror. 1SISINFAErORG yon Scek• Ella! - fl NEWARTY B Si ESWORGf Wa TION. Yo S give .a..,&D O Ss OWNER OF PREVIOUSLY fustian athrle ism. e thst a tAN17.ATgN. Yon s,n pn•mwlex ice Iini1E da0 pascal papery wailed m a *sire IRfJI,WERE EEsY pads alis.I PUNINESS? OAS JANUARY Co I. YOU OUT OF O nerofthe P Syr chat 6Row,s OPasmal Property SOW OPrapW Property Stored Pay Sdygpad; If USW,Sam Price Corer lmewenadter Owwerdex:PeraeaY Properly: - PFIONF! NSYOPERia CH G Aree,ed FAp 1peml Oldy:S NOTE HeoMto mare Rea one New Owns,Pleas Beech aNuki of Near Owen. O PROPERTY CHANGED TO ON DATE: A ITEMIZED LISTING OF L PROPERTY: "FOR THE MOST ACCURATE ASSESSMENT,TF W RECOMMENDED THAT YOU ATTACH - A COMPLETE ITEMIZED ASSET LISTINCIYRII EACH BUSINESS PERSONAL PROPERTY DECLARATION FILM." Neer Include ALL Expensed Asa WYh a Uk.9 Gear This 1 Tar,Fully Deprosea Assets 51E it Use,sod Stored Asset That Are STD AMINO MOM TO WNW I.AritaaR n DRODY. Jeer gERS Depsecyeon. IdaAwelaisRweeonan ITEM YEAR COMPLETE DESCRIPTION INCLUDING YOUR ORIOWAL FACTOR/ SPECIFY ITEM: =1 LD. ACQUIRED MODEL OR CAPACITY INSTALLED COST LIFE NEW OR n NO. USED rnvr 000003 1990 ICI MAC 3,155.00 4/9 a 000007 1994 PREMIER 2,065.00 1/10 E 000010 1994 TIMER 441.00 4/9 Z 000011 1994 RATER DISP 566.00 4/9 000012 1994 SNDRLLNARIS 6,470.00 4/9 . . a t 000013 1994 RITMIlALI • 9,738.00 4/9 g 000014 1994 ISIC.E0WAVI 779.00 4/9 000015 1995 P C IARDNARI 486 2,405.00 13/3 e a 000016 1995 CASH REGISTERS 13,765.00 4/6 , T I 000017 1996 COFFEE BERM SYSTEM 900.00 1/10 E a U 000021 1999 RADIANT RACE OPC SYS 7,098.00 13/3 Q p 000024 1999 CASE ISOT SYSTntS 2,047.00 4/6 K 000025 2000 POI IQUIPIOE6T 2,972.00 13/3 E n 000026 2000 RETAIL IRPTIPIEDIT 3,434.00 4/9 ve 000027 2000 RETAIL 1QDEPIOIT 7,106.00 4/9 1 000026 2001 POD EQOIPkar 4,683.00 13/3 000029 2001 WALK IN COOLER 2,064.00 1/10 JO 1 IP NO ADDI'T'IONS OR DELETIONS CHECK HERE Get THIS RETURN IS SUBJECT TO AUDIT L -rasarer,rrd r•se..rhn.rrrr...s..r..��.l..rr..laa.sr r.r...r revs ra al.al carwr,trW.Iaa5.Cb,r.se,rraYlr ybr.rr.,lr.Yw.Y.r..rWramar.wraws,ara. _�++ ,�rrp,.rrr.�4A.,yrrrrN�r,rr.. rrersa..,rrr.era A Oa' aAr �(AL,,,a,, DATE 3/23/2007 __ mt(210) 32297 HDONAMECSID IONmeMNO John Aranda NAMEOFowsa Valero Diamond Metro, Inc. #4109 UPI a Fat E.MAD.ADORES{ 0 OEM IEEE IP NEW AGENT. IF NEW AGENT.SUMMIT A IETTMI OF AUTHORIZATION Mini HUNG TIES POEM. • - - CONFIDENTIAL ASSESSMENT DATE MAIL.TO: PERSONAL PROPERTY JANUARY 1,2007 WHO CURTIANIESSOR DECLARATION SCHEDULE M00 N.I?AVEGREOEY,CO M61i (Conithetial Data) DUE DATE APRIL 15,2007 Ihem pnm333-NS Fm(9m)3064/3 2007 Sat M IIMD wshiss 8 Return This Copy ASSESSDR'S USE ONLY PLUMS READ INSTRUCTIONS ON RECEIVED RES'ESSE SDI[ G D NON mammon AND MUNN um COPY LATE FILING FEE YES() NO() PIN NUMBER TA CODE BA CODE PARCEL NUMBER P0012612 01160 28045 147106132016 263400002 A NAME AND MARINO AMISS: Valero Diamond Metro,Inc_/4109 .SHOW CHANGES IN NAIVE AND ADDRESS AD VALOREM( TAX DEPT PO BOX 690110 PREVIOUS OWNER'S NAME A ADDRESS SAE ANTOEIO, TX 78269-0110 BMWS NAME AND PHYSICAL LOCATION ass SHOW CHANGES OF PHYSICAL LOCATION: PERSONAL PROPERTY AS OF JANUARY 1.2007 PTT, 15145 ILK 21 TMOSOILYS 8ITO8l -" - l0I D onris. susuasnStyt mi-roRT 1AJ 0W 00000 oq�'1y - C. EM76 3fA�rhseh lM�OYLY). The Ooc�eiu: ProdORwSarice Provided: CIrteTENT OWNER. you re a the merest Wetness owner,chair ha,al P.name and address of U NEW au mI pie a pawn)puperty.Use the Art pat of Section D end math ahem(s)if sealed, le accordssce tea 139.3.119.3,C.R.S.,you ore mot required a Si dech,sioa the total as Sue(deprecate value)ofyo r pawn per clay is S2.500 or hem.Myou to tin gar or are unsure r b whether the aW earl vale of yow pmwl properly per comely exceeds P,500,pia costs te meaty mat'FSe esseaer p�MSses Sr..isle whether er see you We a dedentoa SC isma NEWTDIG ANIZATTON,b.ie sryJ ESSIOR Sardor TION10NSayar give in seams D. o NEW OWNER O►P EVIOUSLY EXISTING 81."SINT&SORrcline.ATION. You man give a complete emliad listing of all persoed property acquired in business paehme, include aNitoae male prior to Jam I emu See pvchp. D AS OF JANUARY 1,WERE YOU OUT OP MINUS? Dyes check followmr OPeaaal Property Sold OPawrl Property Stored De Sdd/Stwsd; If Sold,Npe ad Cape lebrmrion Whew Owen tithe Personal Property: PHONES a If Sad,S ISMS of New O eras. alim hies of Asia d Equipment Only:S • N •OTE:If told a Ewe dah me New Owner.Plww a d,a a PROPBRT4 CHANGED IrE ATIO7 TO: ON DATE; — D. ma to LISTING OP PERSONAL PROPERTY: ••FOR TINE MOST ACCURATE ASSESSMENT,IT IS RECOMMENDED THAT YOU ATTACH A COMPLETE ITEMIZED ASSET LIS INGWITH EACH BUSINESS PERSONAL PROPERTY DECLARATION FILING" New Mende ALL Expensed Asses Willi a Lib of Greer Thee I Yea,Fully Demxiaed Asa Sall in Use,sed Stored Assets That Are a IRS ACeeJm S PRAT TO JMWARY I.ArTAL1 MAWS W mars Sei)eeeDepreciation. trtrAUPrYBue�Prtl0lslY ITEM YEAR COMPLETE DESCRIPTION INCLUDING YOUR ORIGINAL FACTOR/ SPECIFY ITEM: flout J.D. ACQUIRED MODEL OR CAPACITY INSTALLED COST LIFE NEW OR n''LL�r NO. USED AND° 000030 2001 BUYOUT LEASED EQUIPE 3,722.00 4/9 000031 2001 CATHODIC PROTECTION 3,100.00 1/20 000032 2002 MAN 4,590.00 13/3 000033 2002 stemmas 33,362.00 1/10 000034 2002 IOCEAEDIBING EQUIPPER 72,990.00 1/10 - 000035 2002 XCRA DISING DQUIPIO 127,781.00 1/10 000036 2002 GAS TANKS 4,219.00 1/20 000037 2003 COOlPRESSOR 1,601.00 1/10 000031 2003 INSTALL ATG EQUIP 10,155.00 1/20 000039 2003 DIGITAL VID80 RECORD 8,041.00 13/4 .000040 2004 CONVICTION OVEN 2,296.00 1/10 000041 2004 POS EQUIPMENT 16,639.00 13/4 000042 2004 INSTALL P08 EQUIPIET 10,802.00 13/4 000043 2005 COPPER EQUIP 2,606.00 4/9 Il NO ADD177ONS on )ELETIONS CHECK HERE(.l" THIS RETURN IS SUBJECT 1'O AUDIT I. -lS..�.�F.r.S 1w iMasi4wwew..A,Ah.w�.wlisgbe.W,w roes list�Y' W�-I wbbnf.,h-,ate harp�hY/.-Y.Y�,mp�fee�W �l^wa.arril aLwopae W la aw.atw Cw.,gw M/wy.r�AwlY,r,ea NA pwanOl �.�aewwMhwl\MiMl.ww�ewlYw4l.l.wowwwiiY,IMrsi rimUTURE O OWNER Olt AOMrr (l,ji AASU DATE 3/23/2007 ?snJE(210) 345-2297 PRalTXMMOFPWESS3 John Swami?" 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On December 14, 2006, the Statutory Advisory Committee (SAC)to the Property Tax Administrator recommended the attached Chapter 4 for approval and use for 2007. The State Board of Equalization (SBOE) has thirty days to review SAC recommendations. If the SBOE's review results in changes, you will be so advised in a separate memorandum. If you have any questions, please contact the Division at (303) 866-2371. JAG:KLBAtlb G:IOPr-GRPNSCOM\PPFACTORS12007PP FACTORS12007 PP BULLETIN COVER.DOC 1313 Sherman,Room 419,Denver,CO 80203,(303)866-2371 TDD(303)866-5300 FAX(303)866-4000411 E-Mail: oann.groffOstate.co.us 10998 age 9 4.1 CHAPTER 4 PERSONAL PROPERTY TABLES The personal property tables chapter contains the replacement cost factors, economic life estimates, and percent good tables that are provided to assist county assessors in valuing personal property by the cost approach. The level of value adjustment factors are provided pursuant to § 39-1-104(12.3), C.R.S., and must be used to factor assessment date actual values of personal property to the level of value (as of the appraisal date) in effect for real property. The tables and factors published here are subject to verification in the marketplace at the retail "end user" trade level. All cost approach value estimates are based upon the factors and tables found in this section. Cost approach value estimates must be reconciled to the market and income approaches to value based upon the appraiser's opinion as to the reliability of the information used to derive the value estimates from each approach. Reconciliation of the applicable approaches to value is required for the valuation of all personal property in Colorado. Actual Value Determined When. (13Xa)...the cost approach shall establish the maximum value of property if all costs incurred in the acquisition and installation of such property are fully and completely disclosed by the property owner to the assessing officer. (c) ...However,nothing in this subsection(13)shall preclude the assessing officers from considering the market approach or income approach to the appraisal of personal property when such considerations would result in a lower value of the property and when such valuation is based on independent information obtained by the assessing officers. §39-1-103(13),C.RS. For Colorado personal property assessment purposes, the actual value is the value in use, as installed. Colorado statutes require that personal property be valued inclusive of all costs incurred in acquisition and installation of the property. The costs of acquisition, installation, sales/use tax, and freight to the point of use must be considered in the personal property valuation. The inclusion of these costs requires that personal property be valued in use. Therefore,the actual value of personal property is based on its value in use. Counties that develop in-house trending or depreciation tables must submit them annually for approval to the Statutory Advisory Committee to the Property Tax Administrator prior to use. As the property under appraisal ages, the cost approach becomes less indicative of the property value. After fifteen years of age, the recommended valuation procedure is to measure the value of depreciated equipment directly in the marketplace, if possible. 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 998 '10 4.2 COST FACTOR TABLES The replacement cost factor tables are provided to assist the assessor in the determination of replacement cost new estimates by multiplying original or historical cost of personal property by the cost price indexes published and made available through the courtesy of the Marshall Swift Publication Company. When the original cost is multiplied by the factor for the year of acquisition,the product will approximate the current cost to replace,or the Replacement Cost New(RCN),of the personal property being appraised with property having similar utility. The assessor must select the appropriate industry category number that corresponds to the type of equipment being appraised. Thirteen industry category numbers are supplied. In many instances,the individual industry category covers more than one type of commercial or industrial property. Specific types of commercial and industrial property are found in each industry category. If the property to be factored can be specifically identified, the appropriate specific industry category (such as 3 for office equipment) should be applied. If the property cannot specifically be identified, the industry category for the business type may be used. If property is generally useful in many types of business activities, the predominant use shall determine the industry category. If particular property types are not included in the table,a comparable property type industry category number may be selected. The "average of all"(industry category number 1)should be selected if the specific property type is not included in any of the industry categories. After selecting the appropriate industry category number, the assessor uses the specific cost factor that corresponds to the year of acquisition of the equipment. The original cost of the equipment is then multiplied by the cost factor to arrive at the estimated replacement cost new (RCN)as of the assessment date. Example: ersonal Industry Acquisition Cost property- Number l ear Cost Factor RCN Desk 3 2001 $1,500 1.17 $1,755 In other words, it would cost $1,755 on the current assessment date to replace an office desk purchased in 2001 for$1,500. 15-AS-DPr ARL VOL 5 2-89 Rev 1-07 10998 age 11 4.3 INDUSTRY CATEGORY NUMBERS Types of Personal Property Included in Industry Categories Industry Category Table Industry Category Number Property Type 1 Average of All Candy and Confectionery, Creamery and 2 Dairy,Flour, Cereal and Feed,Garage,Meat Packing,Paint, Refrigeration and Rubber 3 Office Equipment,(excluding copiers), and Office Furniture 4 Retail and Wholesale Stores,Warehousing 5 Rental Furnishings, Apartments, Hotels and Motels Banks, Savings and Loans,Restaurants 6 and Lounges, and Theaters 7 Contractors' Equipment 8 Laundry&Cleaning Equipment 9 Bakery,Bottling, Canneries, and Fruit Packing Brewing and Distilling, Cement, 10 Clay Products,Glass,Metal,Logging, Metal Working,Mining and Milling Chemical,Electrical Equipment, 11 Manufacturing,Paper,Motion Pictures and Television,Printing, and Woodworking 12 All Petroleum,and Textile Computer and PC Equipment, 13* Computer-integrated Equipment, Telephone and Telecommunication Equipment,and Copiers Source: Marshall& Swift,October 2006 *Please refer to Chapter 7, Special Issues, under Classification and Valuation of Personal Computers(PCs)and Other Equipment, for more information. CBOE_PP_010998 Page 12 4.4 2007 REPLACEMENT COST NEW FACTORS 2007 PERSONAL PROPERTY COST FACTOR TABLE Industry Cateflory Number Year Acquired 1 2 3 4 5 6 1981 1.88 1.84 1.74 1.87 1.84 1.79 1982 1.80 1.76 1.67 1.80 1.77 1.73 1983 1.76 1.72 1.64 1.75 1.74 1.68 1984 1.72 1.68 1.59 1.70 1.69 1.63 1985 1.69 1.65 1.57 1.67 1.66 1.61 1986 1.68 1.64 1.55 1.65 1.64 1.60 1987 1.65 1.62 1.52 1.62 1.62 1.57 1988 1.58 1.55 1.46 1.56 1.55 1.51 1989 1.50 1.48 1.40 1.48 1.47 1.44 1990 1.46 1.44 1.36 1.44 1.43 1.40 1991 1.44 1.41 1.34 1.42 1.40 1.38 1992 1.42 1.39 1.33 1.40 1.38 1.36 1993 1.39 1.37 1.31 1.36 1.34 1.33 1994 1.35 1.33 1.28 1.32 1.30 1.29 1995 1.31 1.29 1.24 1.28 1.26 1.26 1996 1.29 1.27 1.22 1.26 1.24 1.24 1997 1.27 1.25 1.21 1.24 1.22 1.22 1998 1.26 1.24 1.20 1.23 1.21 1.22 1999 1.25 1.24 1.20 1.23 1.20 1.21 2000 1.23 1.22 1.18 1.20 1.18 1.19 2001 1.22 1.21 1.17 1.20 1.17 1.19 2002 1.21 1.20 1.16 1.19 1.16 1.18 2003 1.19 1.18 1.15 1.17 1.15 1.16 2004 1.15 1.14 1.12 1.13 1.12 1.13 2005 1.07 1.07 1.06 1.06 1.06 1.06 2006 I 1.00 I 1.00 I 1.00 I 1.00 I 1.00 ] 1.00 Source: Marshall& Swift,October 2006 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 1OE_PP_010998 Page 13 4.5 2007 REPLACEMENT COST NEW FACTORS CONTINUED 2007 PERSONAL PROPERTY COST FACTOR TABLE Industry Category Num ber Year Acquired 7 8 9 10 11 12 13 1981 1.86 1.88 1.89 - 1.87 1.85 1.89 1.00 1982 1.76 1.80 1.81 1.77 1.79 1.77 1.00 1983 1.72 1.77 1.79 1.74 1.76 1.75 1.00 1984 1.69 1.72 1.74 1.70 1.71 1.72 1.00 1985 1.67 1.69 1.72 1.68 1.69 1.70 1.00 1986 1.65 1.68 1.71 1.67 1.68 1.70 1.00 1987 1.63 1.65 1.69 1.65 1.67 1.70 1.00 1988 1.58 1.59 1.61 1.60 1.57 1.63 1.00 1989 1.51 1.51 1.52 1.52 1.49 1.55 1.00 1990 1.46 1.47 1.48 1.48 1.46 1.51 1.00 1991 1.42 1.44 1.46 1.45 1.44 1.47 1.00 1992 1.40 1.42 1.44 1.44 1.44 1.46 1.00 1993 1.36 1.40 1.42 1.42 1.43 1.45 1.00 1994 1.33 1.36 1.38 1.39 1.39 1.42 1.00 1995 1.29 1.31 1.33 1.34 1.33 1.37 1.00 1996 1.27 1.29 1.31 1.31 1.31 1.34 1.00 1997 1.25 1.27 1.29 1.30 1.30 1.32 1.00 1998 1.23 1.26 1.28 1.28 1.30 1.30 1.00 1999 1.22 1.26 1.28 1.28 1.30 1.30 1.00 2000 1.20 1.24 1.26 1.26 1.28 1.28 1.00 2001 1.20 1.23 1.24 1.25 1.27 1.26 1.00 2002 1.19 1.22 1.24 1.24 1.27 1.25 1.00 2003 1.17 1.20 1.21 1.21 1.25 1.23 1.00 2004 1.13 1.16 1.17 1.17 1.20 1.18 1.00 2005 1.06 1.07 1.08 1.07 1.10 1.09 1.00 2006 I 1.00 I 1.00 I 1.00 1.00 I 1.00 I 1.00 I 1.00 Source: Marshall& Swift,October 2006 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 398 14 4.6 2007 COST INDEX - FIXTURES/LEASEHOLD IMPROVEMENTS June30,2006 Level of Value This cost index is provided to assist the assessor in relating original or historical costs of fixtures or leasehold improvements to the real property level of value. The property may be valued using real property appraisal records for computations and should be assessed to the owner of record. When using this method of valuation, the property must be classified and abstracted as real property improvements. The factors are useful only in the cost approach when attempting to factor historical costs to the correct level of value. All cost approach value estimates must be reconciled to the sales comparison (market) and income approaches to value as with other real property improvements. The factors found in this table are for estimating replacement costs only and do not include an allowance for depreciation. 2007 FIXTURES/LEASEHOLD IMPROVEMENTS COST FACTOR TABLE Year Acquired Factor 1981 2.09 1982 2.03 1983 1.96 1984 L88 1985 1.83 1986 1.82 1987 1.81 1988 1.77 1989 1.74 1990 1.69 1991 1.67 1992 1.64 1993 1.57 1994 1.51 1995 1.47 1996 1.46 1997 1.41 1998 1.39 1999 1.35 2000 1.28 2001 1.27 2002 1.24 • 2003 1.21 2004 1.13 2005 1.06 2006 1.00 Source: Marshall& Swift,October 2006 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 P_010998 Page 15 4.7 AVERAGE ECONOMIC LIFE ESTIMATES The average economic life estimates are provided for assistance in applying the percent good depreciation tables for each type of property being valued. The economic life recommendations are based upon the Class Life Asset Depreciation Range published by the Internal Revenue Service, Marshall and Swift Co., and other sources. Further information about the estimates may be found in I.R.S. publication 946, "How To Depreciate Property", available from the I.RS. The economic life estimates are based on average national service lives and assume normal use and maintenance of the property. Use of the appropriate economic life estimate accounts for typical physical depreciation and functional/technological obsolescence for the personal property within the valuation process. Use of economic lives that differ from those in the estimates must be documented with specific market information. Counties and taxpayers are encouraged to provide this documentation for review by the Division of Property Taxation for possible update of existing published lives. For specific types of equipment, economic life estimates were developed based on studies completed by the Division of Property Taxation. 15-AS-o r ARL VOL 5 2-89 Rev 1-07 _PP 010998 Page 16 4.8 PROPERTY TYPE Recommended Economic Life (years) COMMERCIAL Wholesale Trade Level Wholesale trade machinery equipment,and furnishings 9 Retail Trade Level Retail trade machinery equipment,and furnishings 9 Service Trade Level Adding machines, calculators 6 All terrain vehicles(ATVs)For addt'1 info.,see Chapter 7 6 Amusement parks 12 Automated teller machines (ATMs): see Chapter 7 Computer/electronic components/portion 4* Structural housing 10 Auto repair shops 10 Bank vault doors 20 Barber and beauty shops 10 Cable television: Digital TV set-top boxes 4* Subscriber converters,other than digital 5 Test equipment 8 Origination equipment 9 Satellite receiving ground stations 9 Distribution&subscriber connection equipment 10 Headend equipment 11 Microwave systems 9 Computers—personal&accessories 3* Computers—other&stand-alone peripherals 4* Computer—integrated machinery&equipment 4 Construction equipment, general 6 Copiers and duplicators 6** Data handling equipment,except computers 6 Electronic equipment, except computers or gaming 6 Gaming: see Chapter 7 Electronic(e.g. slot machines) 5 Larger gaming personal property(e.g. tables) 10 Gas station equipment Electronic fuel pumps 6 General 10 Tanks (e.g. above ground,propane,septic) 10 Tanks (e.g. below ground,double-walled,fuel) 20 Hydroelectric Generators 20 Golf carts 6 Laundry and dry cleaning 10 Commercial Continued on next page * Use appropriate computer percent good table 2007. ** Use the copier percent good table 2007. Source:Division of Property Taxation,Marshall& Swift, &IRS. 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 010998 'age,, 4.9 PROPERTY TYPE Recommended Economic Life (years) COMMERCIAL(continued) Service trade level(continued) Medical equipment:For addt'l info.see Chapter 7 3 to 10 Meter and stamp equipment 6 Office furniture 10 Pedicabs 10 Photo processing equipment(Electronic) 6 Pod-a-potty 10 Radio and television broadcasting 6 Recreation and amusement 10 Restaurant and bar(all) 10 River Rafts 10 Shopping carts 5 Signs (Billboard and Monument) 20 Signs (Other) 10 Snow cats: For addt'l info.see Chapter 7 Heavy use(e.g. snowgrooming operations) 6 Moderate use(e.g. transportation operations) 10 Storage tanks: Tanks(e.g. above ground,propane,septic) 10 Tanks (e.g. below ground,double-walled,fuel) 20 Telecommunication machinery and equipment 4 Theater 10 Telecommunication towers 20 Typewriters 6 Vending machines 10 Video machines(arcade) 6 RESIDENT IAL/COMMERCIAL Residential rental furnishings 10 Apartment,hotel and motel furnishings 10 NATURAL RESOURCES Minim-Metallic and Nonmetallic Mining, quarrying,&milling equipment 10 Petroleum and Natural Gas Exploration,drilling 6 High-technology drilling rigs 10 Production(Excluding pipelines) 14 Marketing,retail 9 Refining 16 Timber Logging 6 Sawmills,permanent 10 Sawmills,portable 6 Source:Division of Property Taxation,Marshall&Swift &LR.S 15-AS-DPT Alt VOL 5 2-89 Rev 1-07 CBOE_PP_g10998 Page 18 4.10 PROPERTY TYPE Recommended Economic Life (years) INDUSTRIAL Manufacturing Trade Level Aerospace 10 Apparel and fabricated textiles 9 Bakeries and Confectionery 12 Brewery 12 Canneries and frozen food 12 Cement manufacture 20 Cereal,flour,grain and mill products 17 Chemicals and related products 10 Clay and gypsum products 15 Concrete manufacture 15 Dairy products manufacturing 12 Electrical equipment manufacturing 10 Electronic equipment manufacturing 6 Fabricated metal products 12 Special tools 3 Food and beverae production 12 Special handling devices 4 Forklifts 10 Glass and glass product 14 Special tools 3 Jewelry 12 Lumber,wood products and furniture 10 Machinery (not otherwise listed in this section) 10 Meat packing 12 Motion picture and television production 12 Paint and varnish 10 Plastics and plastic products 11 Special tools 3 Printing and publishing 11 Professional and scientific instruments 10 Paperboard and pulp 10 Rubber products 14 Special tools 4 Semi-conductor manufacturing: General 5 Research and development 3 Test equipment 5 Wafer fabrication 3 Soft drink bottling 12 Steel and related products 15 Stone products 15 Sugar and sugar products 18 Source: Division of Property Taxation,Marshall& Swift, &I.R.S. 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 :BOE_PP_010998 Page 19 4.11 PERCENT GOOD TABLE The personal property percent good table is provided to assist the assessor in estimating the replacement cost new less normal depreciation (RCNLD). The column headings represent the average service life expectancy of the personal property being appraised. Each column contains the percent good factor for a specified age in the life of the property. Percent good tables measure the value remaining in personal property. Depreciation tables measure the loss in value at a specified age. The factor shown in the columns of the percent good table represents the percentage of RCN remaining at a specified age. The general percent good tables are built upon the following assumptions: 1. Iowa State University property retirement& depreciation studies 2. A specified rate of return 3. Average condition and usage of typical property The general percent good table is generic in nature. It was designed to be generally useful for the majority of personal property. It is not specific to any particular industry or type of personal property. The table was designed to account for normal physical depreciation. Use of the table with the appropriate economic life estimate accounts for typical physical depreciation and functional/technological obsolescence for the personal property within the valuation process. Additional functional/technological and/or economic obsolescence may also exist. If documented to exist, additional functional and economic obsolescence must be measured in the marketplace either using the market approach or rent loss methods. In addition, any adjustments to the percent good due to the condition of the subject property must be defensible and documented. The minimum percent good shown for each of the colunms is useful as a guide to residual value. It is not absolute and must be reconciled with value in use infonnation at the retail "end user"trade level for similar types of property. If the market information shows that the actual value of personal property is lower than the value developed by using the minimum percent good, the use of the minimum percent good should be rejected in favor of the lower value. The actual value of the personal property must be determined as long as the personal property is taxable. If the cost-calculated value is lower than the market and/or income approach developed value in use, when the personal property reaches its minimum percent good, the assessor should review the original cost, all assigned factors, the physical condition of the property,and other pertinent contributors to value. If these are correct, the assessor must use the cost approach value as the actual value of the personal property pursuant to § 39-1-103(13Xa),C.R.S. As the personal property under appraisal ages, the cost approach becomes less indicative of the property value. After fifteen years of age. the recommended valuation procedure is to measure the value of depreciated equipment directly in the marketplace, if possible. To use the table, the assessor must determine the economic life and the effective age of the subject property. The percent good may be determined by moving across the columns until the one specified for the economic life is reached and then down this column to the point that reflects the effective age of the property. 15-A5-OPT ARL VOL 5 2-89 Rev 1-07 .BOE_PP_010998 Page 20 4.12 Example: Fr ersonal Economic Percent operty Lire Age RCN Good RCNLD Desk 10 years 6 years $1,755 55% $965 The assessor must also consider functional and economic obsolescence, abnormal physical condition, or other factors that might affect the value of the equipment. The assessor should also consider the frequency and extent of maintenance to the property. Extensive maintenance or reconditioning of the property may extend the economic life of the property just as a lack of maintenance may shorten the economic life. DEPRECIATED VALUE FLOOR, In the year in which the personal property has reached its minimum percent good, the applicable Replacement Cost New (RCN) trending factor in use at that time is "frozen" and the Level of Value(LOV) adjustment factor is "frozen"at 1.0. For the assessment years that follow, the RCNLD value does not change until the personal property is permanently taken out of service. An exception to this rule applies when the property has been reconditioned to extend its remaining economic life. Even though the personal property has been permanently taken out of service, but has not been scrapped or sold, it still has value. However, additional functional and/or economic obsolescence may exist. It is possible that the market or income approach may indicate a lower value than the personal property's minimum percent good. In addition,as property ages, the use of original installed cost multiplied by trending factors may not yield reasonable RCN values. Any RCNLD estimate should be crosschecked with sales comparison (market) and income infonnation sources, if possible, and the appropriate value used. VALUATION OF USED PERSONAL PROPERTY The valuation of used personal property requires that a decision be made concerning the remaining economic life of the property. If the personal property's elapsed age from its actual year of manufacture, or estimated effective year of manufacture, is equal to or greater than the number of years in which the personal property would have reached its fully depreciated value floor, then the price paid for the personal property is to be treated as RCNLD and "frozen" at that value. RCN trending and percent good factors will not be applied to the frozen value. The LOV adjustment factor is "frozen"at 1.0 and will remain 1.0 until the property is taken out of service, sold,or retired. An exception to this rule applies when the personal property is reconditioned to extend its remaining economic life. Then the reconditioned property is treated as new personal property and the formerly frozen value is treated as acquisition cost that is subject to depreciation over a complete economic life of the personal property. Even though personal property has been permanently taken out of service, but has not been scrapped or sold, it still has value. However, additional functional and/or economic obsolescence may exist. 15-AS-OPT ARL VOL 5 2-89 Rev 1-07 CBOE_PP_010998 Page 21 4.13 If the elapsed age from the year of manufacture, or estimated effective year of manufacture, is less than the number of years when the personal property would have reached its depreciated value floor, as evidenced in its recommended economic life from the preceding tables, then the property is treated as new personal property and the owner's acquisition cost is subject to depreciation over the complete economic life as would be used for new personal property. However,the resulting value should be compared to the sales comparison(market) value for the personal property,if possible. 2007 GENERAL PERCENT GOOD TABLE AVERAGE ECONOMIC LIFE IN YEARS 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 1 69 78 83 87 89 91 92 94 94 95 96 96 97 97 98 98 98 98 2 39 55 65 72 77 81 84 87 89 90 91 92 93 94 95 95 96 96 3 18 35 48 58 65 71 76 79 82 85 87 88 90 91 92 93 94 94 4 15 19 32 44 53 61 67 71 75 79 81 84 86 87 89 90 91 92 5 15 20 32 41 51 57 63 68 72 76 79 81 83 85 87 88 90 6 15 21 31 40 48 55 61 66 70 74 77 80 82 84 85 87 7 15 22 32 40 47 54 60 64 68 72 75 78 80 82 84 8 15 23 32 39 47 52 58 63 67 71 74 77 79 81 • 9 15 24 32 39 46 52 57 62 66 69 73 76 78 c. 10 15 25 32 40 45 51 56 62 65 69 72 75 11 15 26 32 40 46 52 57 60 65 69 72 12 22 27 33 40 46 51 55 60 65 68 • 13 15 24 29 36 40 46 49 56 61 64 14 15 26 30 36 42 46 52 57 60 U 15 20 24 31 37 43 48 52 56 • 16 15 22 25 32 38 43 48 52 w 17 15 24 27 33 39 44 48 w 18 15 26 28 34 39 44 19 22 24 30 35 40 20 15 20 26 31 36 21 19 22 28 33 22 15 19 24 30 23 15 21 27 24 15 24 25 21 26 15 Source:Division of Property Taxation 15-AS-OPT ARL VOL 5 2-89 Rev 1-07 CBOE_PP_010998 Page 22 4.14 Using market studies, the following table has been developed for Personal Computers (PCs) and Accessories: Percent Good Table 2007 Average Economic Life ?tee 3 EFF 1 44 2 23 A 3 13 G 4 7 E Source: Division of Property Taxation Using market studies, the following table has been developed for Other Computer Equipment Including Computer Peripherals: Percent Good Table 2007 Average Economic Life Aee 4 EFF 1 50 2 36 A 3 22 G 4 13 E 5 7 Source: Division of Property Taxation For personal property classified as Computer-integrated Machinery and Equipment, a four (4) year economic life is assigned. The four (4) year life depreciation table found in the General Percent Good Table in this section should be used. If you have questions concerning personal computers (PCs) and accessories, other computer equipment including stand-alone computer peripherals, or computer-integrated machinery and equipment, please refer to Chapter 7, Special Issues, under Classification and Valuation of Personal Computers(PCs) and Other Equipment. 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 CBOE_PP_010998 Page 23 4.15 Using market studies,the following table has been developed for Copiers: Percent Good Table 2007 Average Economic Life Aee 6 EFF 1 54 2 46 A 3 36 G 4 32 E 5 29 6 26 7 20 Source: Division of Property Taxation Copiers have a six(6)year economic life and should be"frozen"in the seventh year at the 20 percent good. In the seventh year the LOV adjustment factor is "frozen" at 1.0 and will remain 1.0 until the personal property is taken out of service,sold, or retired. 15-A5-OPT ARL VOL 5 2-89 Rev 1-07 CBOE_PP_010998 Page 24 4.16 LEVEL OF VALUE ADJUSTMENT FACTORS The following table contains the indexes for adjusting current actual value of personal property to the level of value (LOV) in effect for real property as specified by § 39-1-104(12.3XaXI), C.R.S. The procedure involves the multiplication of the assessment date actual value estimate by the appropriate LOV factor for the type of property being valued. When personal property reaches its fully depreciated value floor the actual value should be determined and frozen. The LOV adjustment factor is "frozen" at 1.0 and will remain 1.0 until the property is taken out of service, sold,or retired. Example: ersonal Industry LOV Actual re Pert)? Number Age RCNLD Factor Value Desk 3 6 years $965 0.98 $946 2007 PERSONAL PROPERTY LOV FACTOR TABLE June 30,2006 Level of Value Industry Number LOV Factor 1 0.98 2 0.98 3 0.98 4 0.98 5 0.99 6 0.98 7 0.99 8 0.98 9 0.98 10 0.98 11 0.97 12 0.98 13 1.00 Source: Division of property Taxation and Marshall 8c Swift` 15-AS-DPT ARL VOL 5 2-89 Rev 1-07 CBOE_PP010998 Page 25 . ... . b",:,bBURLESON COOKE LLR ATTORMITS A ADVISORS C6mtopbe.C.Rook. Diva Dial 713-354-1712 D sgell i13•]SFm1 3m.hl3a..otmm RECEIVED July 3,2007 JUL 03 2007 Via Hand Delivery WELD COUNTY ASSESSOR Mr. Christopher N. Woodruff GREELEY, COLORADO Weld County Assessor 1400 N. 176 Avenue Greeley,Colorado 80631 RE: Letter of Objection and Protest(PP)Year 2007;Position Papers in Support of Proposed Valuations. Dear Mr. Woodruff: This letter is being submitted in support of the letter of objection and protest regarding personal property filed with your office for tax year 2007 for the taxpayers reflected in Exhibit "A". Taxpayers set forth in the body of these working papers, in part, their explanation in support of proposed valuations. Determination of Actual Value Underground fuel storage tanks ("UST") owned by these taxpayers in Weld County constitute a significant portion of taxpayers' personal property assessed by the Weld County Assessor. Taxpayers' business personal property must be assessed based on its actual value. Under Colorado law, actual value is synonymous with market value. Market value represents what a willing buyer would pay a willing seller under normal economic conditions. In other words,the most probable price for which the appraised property will sell in a competitive market under all conditions requisite to a fair sale. Although Colorado statutes require the application of the cost, market and income approaches to appraisal where applicable, the Constitutional mandate is to determine the property's actual value. As such,the ultimate determination must be what a willing buyer would pay a willing seller for the business personal property. According to the Division of Property Taxation ARL's, which the assessors are bound to comply with, the assessor must examine the "characteristics and condition of [a parcel of] property" to determine a "clear, current and detailed description of the subject property before estimating value." If circumstances exist under which the three (3) appraisal methods do not provide a clear basis for determining actual value, the assessor should look to all existing MOW 53641.0 711 Loulaato Sheet.Suite 1701 • Houston.Texas 77002 Telephone: 713.358.1700 Foe: 713.368.1717 )10998 age 26 information in an effort to ensure that its determination of actual value is accurate"to the extent which is equitably and practically possible." It is only by the examination and consideration of all information that the true nature and physical condition of the personal property may be determined. Based on the unique characteristics of a UST, the cost, market and income approaches, as employed by the Weld County Assessor's Office, do not provide an accurate basis for determining what a willing buyer would pay a willing seller. Based on the physical characteristics and regulatory requirements regarding UST's in Colorado, the value of a used UST as measured by the willing buyer-willing seller standard is virtually zero. There is no question that during the removal process the vast majority of UST's cannot maintain structural integrity and will disintegrate. Assuming for the purposes of argument that a used UST were to maintain its structural integrity upon removal, a hypothetical buyer must comply with federal and state regulations regarding the inspection, licensing and recertification of a UST prior to reuse. Furthermore, costs arising from the obligatory administrative, licensing and certification measures may be substantial,and would necessarily be taken into consideration by any willing buyer. These obligatory requirements are cost prohibitive and result in a practical situation in which no rational willing buyer will purchase a used UST and incur the loss and/or potential liability. The UST's owned by taxpayers are of various ages, but all have been subjected to petroleum substances for a period of time sufficient to result in the presence of residual amounts of these materials within the personal property itself. Any resale of a UST would entail a willing buyer expending significant amounts to remove, transport, test, recertify and relicense the UST being purchased. For example,Colorado Department of Labor and Employment,Division of Oil and Public Safety Storage Tank Regulations require the performance of numerous measures prior to the removal and/or replacement of a UST. Any party removing or replacing a UST must notify the Director of its intended action. Upon removal,that patty must ensure that all residual fuel materials have been removed so that no more than 2.5 centimeters (one inch) of residue, or .3 percent by weight of the total capacity of the UST remain in the system. Further, the party must measure for the presence of a release from the UST where contamination is most likely to be present at the site. This process necessarily entails detailed and very costly excavation and testing of soils. Extensive records must be maintained by the seller demonstrating compliance with excavation and closure requirements under Colorado law. Finally the underground storage tank itself must be removed. A UST tank owner is obligated to perform these measures by state and/or federal law. These statutory obligations are by no means an all inclusive list, and the actual measures required may be much more burdensome. These measures result in significant transactional costs which are passed on to a buyer by the seller of a used UST. In an effort to deny the real world effect of these regulatory obligations upon the marketplace, the assessors have substituted cost for actual value. As a result, the assessors' valuation of taxpayer's business personal property does not reflect what a willing buyer would pay a willing seller for the property, and are thus, erroneous. The reality of the marketplace is that for much of taxpayer's business personal property,little to no market exists. As a result,any determination of actual value by the Weld County Assessor's Office which fails to consider the effect of these regulatory obligations and the physical characteristics of a used UST, and to allocate an appropriate deduction to the actual value, is erroneous based on the express (0001B 6M) i1 CBOE_PP 010998 Page 27 provisions of the Colorado Constitution, statutes, case law and Division of Property Taxation ARL's. Respectfully Submitted, art C. Christopher C.Rosas CO Bar No.: 33018 BURLESON COOKE,L.L.P. 711 Louisiana St.,Ste.711 Houston,Texas 77002 (Voice): 713.358.1712 (Facsimile) 713.358.1717 Attorney for Taxpayer, Diamond Shamrock Stations,Inc. and Valero Diamond Metro,Inc. Exhibit"A" Taxpayers and Schedule Numbers Diamond Shamrock Stations,Inc. Schedule Numbers(PP): P0009071 095913300008; P0014846 096131416003; Valero Diamond Metro,Inc. Schedule Number(PP): P0012682 147106132016. -End- CBOE_PP 010998 Page 28 PANEL ON OONSOLIDATRD IIOLTIDISTRICT LITIGATION _ - Colorado Supreme Court D Two E. 14th Ave. , 4th Floor WWI Denver, CO 80203 jO FEB 1S71MI7 iscouwry DISTRICT COURT, ADAMS COUNTY, COLORADO ATTORNEYS OFFICE Case No. 06 CV 1147 Plaintiffs: Case No:07MDLOB VALERO DIAMOND METRO, INC. , DIAMOND SHAMROCK REFINING AND MARKETING COMPANY, DIAMOND SHAMROCK STATIONS, INC. , and AUTOTRONICS SYSTEMS, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF ADAMS COUNTY, acting as the BOARD OF EQUALIZATION, and GIL REYES, TAX ASSESSOR OF ADAMS COUNTY. DISTRICT COURT, ARAPAHOE COUNTY, COLORADO Case No. 06 CV 4921 Plaintiffs: VALERO DIAMOND METRO INC. , DIAMOND SHAMROCK STATIONS, INC. , and TOC-DS COMPANY, v. Defendants: BOARD OF COUNTY COMMISSIONERS OF ARAPAHOE COUNTY, acting as the BOARD OF EQUALIZATION, and EDWARD HOSIER, TAX ASSESSOR OF ARAPAHOE COUNTY. CBOE_PP010998 Page 29 PANEL ON CONSOLIDATt MOL TIDISTRICT LITIGATION Colorado Supreme Court Two E. 14°° Ave. , 4a Floor Denver, CO 80203 DISTRICT COURT, BOULDER COUNTY, COLORADO Case No. 06 CV 1130 Plaiati!!• Case Na 07MDL08 (CaatYd) VALERO DIAMOND METRO, INC. , DIAMOND SHAMROCK STATIONS, INC. , DIAMOND SHAMROCK REFINING AND MARKETING COMPANY, and TOC-DS COMPANY, v. Defendants: BOARD OF COUNTY COMMISSIONERS OF BOULDER COUNTY, acting as the BOARD OF EQUALIZATION, and CINDY DOMENICO, TAX ASSESSOR OF BOULDER COUNTY_ DISTRICT COURT, BROOMFIELD COUNTY, COLORADO Case No. 06 CV 243 Plaintiffs: DIAMOND SHAMROCK STATIONS, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF BROOMFIELD COUNTY, acting as the BOARD OF EQUALIZATION, and VICKIE BROWN, TAX ASSESSOR OF BROOMFIELD COUNTY. CBOE_PP_010998 Page 30 PANE, ON CONSOLIDATED NOLTIDISTRICT LITIGATION Colorado Supreme Court Two B. 14th Ave. , 4te Floor Denver, CO 80203 DISTRICT COURT, CLEAR CREEK COUNTY, COLORADO Case No. 06 CV 95 Plaintiffs: Case Na OIMDL08 (Confd) VALERO DIAMOND METRO, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF CLEAR CREEK COUNTY, acting as the BOARD OF EQUALIZATION, and DIANE SETTLE, TAX ASSESSOR OF CLEAR CREEK COUNTY. DISTRICT COURT, DENVER COUNTY, COLORADO Case No. 06 CV 9507 Plaintiffs VALERO DIAMOND METRO INC. , and DIAMOND SHAMROCK STATIONS, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF DENVER COUNTY, acting as the BOARD OF EQUALIZATION, and" JOHN RAGAN, TAX ASSESSOR OF DENVER COUNTY. CBOE_PP_010998 Page 31 PANEL ON CONSOLIDATED MCLIZDISTRICT LITIGATION Colorado Supreme Court Two E. 14tk Ave. , 4th Floor Denver, CO 80203 DISTRICT COURT, DOUGLAS COUNTY, COLORADO Case No. 06 CV 1815 Plaintiffs: Gee Na 07MDL08 (Cartd) VALERO DIAMOND METRO, INC. , and DIAMOND SHAMROCK STATIONS, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF DOUGLAS COUNTY, acting as the BOARD OF EQUALIZATION, and EDITH N. BOY, a/k/a NIKKI HOY, TAY ASSESSOR OF DOUGLAS COUNTY.. DISTRICT COURT, EL PASO COUNTY, COLORADO Case No. 06 CV 3715 Plaintiffs: VALERO DIAMOND METRO INC. , DIAMOND SHAMROCK STATIONS, INC. , and DIAMOND SHAMROCK REFINING AND MARKETING COMPANY, v. Defendants BOARD OF COUNTY-tOIMISSIONERS OF EL PASO COUNTY, acting as the BOARD OF EQUALIZATION, and JOHN BASS, TAX ASSESSOR OF EL PASO COUNTY. CBOE_PP_010998 Page 32 PANEL ON CONSOLIDATED M0LTIDISTRICT LITIQATION Colorado Supreme Court Two E. 14th Ave. , 4Th Floor Denver, CO 80203 DISTRICT COURT, GARFIELD COUNTY, COLORADO Case No. 06 CV 293 Plaintiffs Can Na 07MDI.08 (Cad) VALERO DIAMOND METRO, INC. , v. Defendants: HOARD OF COUNTY COMMISSIONERS OF GARFIELD COUNTY, acting as the BOARD OF EQUALIZATION, and SHANNON HURST, TAX ASSESSOR OF GARFIELD COUNTY. DISTRICT COURT, JEFFERSON COUNTY, COLORADO Case No. 06 CV 4492 Plaintiffs, VALERO DIAMOND METRO INC. , DIAMOND SHAMROCK STATIONS, INC. , DIAMOND SHAMROCK REFINING AND MARKETING COMPANY, v. Defendants, BOARD OF COUNTY COMMISSIONERS OP JEFFERSON COUNTY, acting as the BOARD OF EQUALIZATION, and JIM EVERSON, TAX ASSESSOR OF JEFFERSON COUNTY. CBOE_PP 010998 Page 33 PANEL ON CONSOLIDAITn') MULTIDISTRICT LITIGATION Colorado Supreme Court Tiro E. 14th Ave. , 4th Floor Denver, CO 80203 DISTRICT COURT, LA PLATA COUNTY, COLORADO Case No. 06 CV 185 Plaintiffs Cue Na 07MDLA8 . pinged) VALERO DIAMOND METRO, INC: , V. Defendants: BOARD OF COUNTY COMMISSIONERS OF LA PLATA COUNTY, acting as the BOARD OF EQUALIZATION, and CRAIG N. LARSON, TAX ASSESSOR OF LA PLATA COUNTY. DISTRICT COURT, LASE COUNTY, COLORADO Case No. 06 CV 47 Plaintiffss DIAMOND SHAMROCK STATIONS, INC. , v. Dsfendantss BOARD OF COUNTY COMMISSIONERS OF LAKE COUNTY, acting as the BOARD OF EQUALIZATION, and HOWARD TRITZ, TAX ASSESSOR OF LAZE COUNTY. CBOE_PP_010998 Page 34 PANEL ON CONSOLIDATED MUUPIDIBTRICT LITIGATION Colorado Supreme Court Two E. 14`k Ave. , 4th Floor Denver, CO 80203 DISTRICT COURT, LARIMER COUNTY, COLORADO Case No. 06 CV 781 Plaintiffs* Ca m Na 07MDI.08 (Cantd) VALERO DIAMOND METRO, INC. , DIAMOND SHAMROCK STATIONS, INC. , and DIAMOND SHAMROCK REFINING AND MARXETING COMPANY, v. Defendants: BOARD OF COUNTY COMMISSIONERS OF LARIMER COUNTY, acting as the HOARD OF EQUALIZATION, and LARRY G. JOHNSON, TAX ASSESSOR OF LARIMER COUNTY. DISTRICT COURT, MESA COUNTY, COLORADO Case No. 06 CV 330 Plaintiffs VALERO DIAMOND METRO, INC. , v. Delaadantss BOARD OF COUNTY COMMISSIONERS OF MESA COUNTY, acting as the BOARD OF EQUALIZATION, and CURTIS BELCHER, TAX ASSESSOR OF MESA COUNTY. CBOE_PP_010998 Page 35 PANEL ON CONSOLIDATED MOLTXDISTRICT LITIGATION Colorado Supreme Court Two S. 14th Ave. , 4th Floor Denver, CO 80203 DISTRICT COURT, PUEBLO COUNTY, COLORADO Case No: 06 CV 1385 Plaintiffs: Case Na:07MDI.08 (Cantd) VALERO DIAMOND METRO, INC. , and DIAMOND SHAMROCK REFINING AND MARKETING COMPANY, v. ; Defendants: BOARD OP COUNTY COMMISSIONERS OF PUEBLO COUNTY, acting as the BOARD OF EQUALIZATION, and VICTOR E. PLUTP, TAX ASSESSOR OF PUEBLO COUNTY. DISTRICT COURT, SUMMIT COUNTY, COLORADO Case No. 06 CV 230 Plaintiffs: VALERO DIAMOND METRO, INC., and DIAMOND SHAMROCK REFINING AND MARKETING, v: Defendants: BOARD OF COUNTY COMMISSIONERS OF SUMMIT COUNTY, acting as the BOARD OF EQUALIZATION, and DENISE STEISKAL, TAX ASSESSOR OF SUMMIT COUNTY. CBOE_PP_010998 Page 36 PANEL ON CONSOLIDATE )CLTIDISTRICT LITIERTION Colorado Suprens Court Tiro E. 14th Ave. , 4th Floor Denver, CO 80203 DISTRICT COURT, TELLER COUNTY, COLORADO Case No. 06 CV 206 Plaintiff: Case No:7MDLD6 (Caned) DIAMOND SHAMROCK STATIONS, INC. , v. Defendants: BOARD OF COUNTY COMMISSIONERS OF TELLER COUNTY, acting as the BOARD OF EQUALIZATION, and ALAN JORDAN, TAX ASSESSOR OF TELLER COUNTY. DISTRICT COURT, MELD COUNTY, COLORADO Case No. 06 CV 630 Plaintiffs: VALERO DIAMOND METRO, INC. , and DIAMOND SHAMROCK STATIONS, INC. , v. . Defendants: HOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, acting as the. BOARD OF EQUALIZATION, and STAN SESSIONS, TAX ASSESSOR OF WELD COUNTY. CERTIFICATION TO THE CHIEF JUSTICE PURSUANT TO C.R.C.P. 42.1(h) CBOB_PP_010998 Page 37 Upon review of the Movants, Valero Diamond Metro, Inc. , Diamond Shamrock Refining and Marketing Company, Diamond Shamrock Stations, Inc. , TOC-DS Company and Autotronic Systems, Inc. •s Unopposed Motion for Transfer and Consolidation Pursuant to C.R.C.P. 42.1, and now being sufficiently advised in the premises, IT IS THE DETERMINATION of the Panel that the above- referenced actions should be consolidated pursuant to C.R.C.P. 42.1 and that venue is proper in Douglas County. THE PANEL HEREBY CERTIFIES these actions to the Chief Justice pursuant to C.R.C.P. 42.1(h) and recommends that the Honorable Paul A. Ring, judge of the Eighteenth Judicial District, be assigned to hear these consolidated matters. IT IS ORDERED that all further proceedings in the district courts shall be stayed pending the Order Pursuant to C.R.C.P. 42.1(i) by the Chief Justice. BY THE PANEL, February 14, 2007. SUSAN J. FESTAG Clerk of the Panel its=r.,, t1 Chi puty Clerk CBOE_PP_010998 Pape 38 Copies mailed via the State's Mail Services Division on 2/14/07. LR Christopher Roses Robert D. Clark 711 Louisiana St. , Ste. 1701 Assistant County Attorney Houston, TX 77002 100 Third Street Castle Rock, CO 80104 Joseph Fattor Don K. DeFord P.O. Box 221 108 8`e Street, Ste. 219 Leadville, CO 80461 Glenwood Springs, CO 81601 Paul W. HurcoMb Franklin P. Calico 24 South Weber, Ste. 400 208 E. Lincoln Avenue Colorado Springs, CO 80903 P.O. Box 68 Breckenridge, CO 80424 Cyndy Giauque Robert W. Loeffler 915 Tenth Street P.O. Box 2000 P.O. Box 758 Georgetown, CO 80444 Greeley, CO 80632 Valerie J. Robison May Taylor P.O. Box 20,000 201 West Colfax, Dept. 1207 Grand Junction, CO 81502 Denver, CO 80202 Michael A. Eoertje Michael A. Goldman P.O. Box 471 679 Bast Second Avenue, Ste. C Boulder, CO 80306 Durango, Co 81301 Writer Mott John N. Franklin 100 Jefferson County Parkway 27 Bast Vermijo Avenue Golden, Co 80419 Colorado Springs, CO 80903 Tani Yellico Jeannine S. Haag One DesCombes Drive Ninth Floor, First Tower Bldg. Broomfield, CO 80020 P.O. Box 1606 Fort Collins, CO 80522 Daniel C. Kogovsek Jennifer Wascak 215 West 10a Street 450 South 4a Avenue Pueblo, Co 81003 Brighton, CO 80601 CBOE_PP_010998 Page 39 George Rosenberg Clerk of the Combined Court 5334 South Prince Street Adams County Justice Center Littleton, CO 80166 1100 Judicial Center Dr. Brighton, CO 80601 Honorable Thomas Halsor Honorable Cheryl L. Post Adams County Justice Center Arapahoe County Justice Cent. 1100 Judicial Center Dr. 7325 S. Potomac St. Brighton, CO 80601 Centennial, CO 80112 Clerk of the District Court Honorable Maria K. Berkenkotter Arapahoe County Justice Cent. Boulder County District Court 7325 S. Potomac St. P.O. Box 4249 Centennial, CO 80112 Boulder, CO 80306 Clerk of the Combined Court Honorable Chris Melonakis Boulder County District Court Broomfield County Court P.O. Box 4249 17 DeCombes.Dr. Boulder, CO 80306 Broomfield, CO 80020 Clerk of the Court Honorable Russell H. Granger Broomfield County Court Clear Creek District Court 17 DeCombes Dr. P. O. Box 367 Broomfield, CO. 80020 Georgetown, CO 80444 Clerk of the Combined Court Honorable Sheila A. Rappaport Clear Creek District Court Denver District Court P. O. Box 367 1437 Bannock Street, Rn. 256 Georgetown, CO 80444 Denver, CO 80202 Clerk of the Combined Court . Honorable Paul A. King Denver District Court Douglas County District Court 1437 Bannock Street, Rm. 256 4000 Justice Nay, Ste. 2009 Denver, CO 80202 Castle Rock, CO 80109 Clerk of the Combined Court Honorable Edward S. Colt Douglas County District Court El Paso County District Court 4000 Justice Way, Ste. 2009 20 B. Vermijo Avenue Castle Rock, CO 80109 Colorado Springs, CO 80903 Clerk of the Combined. Court Honorable Daniel B. Petre El Paso County District Court Garfield County Courthouse 20 E. Vermijo Avenue 109 8°h St. , Ste. 104 Colorado Springs, CO 80903 Glenwood Springs, CO 81601 CBOE_PP_010998 Page 40 Clerk of the Combined Court Honorable Christopher J. Munch Garfield County Courthouse Jefferson County District Court 109 8th St. , Ste. 104 100 Jefferson County Parkway Glenwood Springs, CO 81601 Golden, CO 80401 Clerk of the Combined Court Honorable David L. Dickinson Jefferson County District Court La Plata County District Court 100 Jefferson County Parkway 1060 Bast 2"d Avenue Golden, CO 80401 Durango, Co 81301 Clerk of the Combined Court Honorable David R. Lass La Plata County District Court Lake County District Court 1060 Bast 2" Avenue P.O. Box 55 Durango, Co 81301 Leadville, CO 80461 Clerk of the Combined Court Honorable Terence A. Gilmore Lake County District Court Larimer County Justice Center P.O. Box 55 201 La Porte Ave. , Ste. 110 Leadville, CO 80461 Fort Collins, CO 80521 Clerk of the Court Honorable Brian J. Flynn Larimer County Justice Center Mesa County District Court 201 La Porte Ave. , Ste. 110 P.O. Box 20,000 Fort Collins, CO 80521 Grand Junction, CO 81502 Clerk of the Combined Court Honorable Dennis Maes Mesa County District Court Pueblo Cty Judicial Bldg P.O. Box 20,000 320 N. 10th St. Grand Junction, CO 81502 Pueblo, CO 81003 Clerk of the Combined Court Honorable David R. Lass Pueblo Cty Judicial Bldg Summit County District Court 320 N. 10th St. P.O. Box 269 Pueblo, CO 81003 Breckenridge, CO 80424 • Clerk of the District Court Honorable Thomas L. Kennedy Summit County District Count Teller-County Courthouse P.O. Box 269 P.O. Box 2980 Breckenridge, CO 80424 Cripple Creek, CO 80813 Clerk of the Combined Court Honorable Roger A. Klein Teller County Courthouse Weld County District Court P.O. Box 2980 P.O. Box 2038 Cripple Creek, CO 80813 Greeley, CO 80632 CBOE_PP 010998 Page 41 Clerk of the Court Weld County District Court P.O. Box 2038 Greeley, CO 80632 Honorable Harlan Boom Chair, MDL Panel CBOE_PP_010998 Page 42 NOTICE OF DENIAL OFFICE OF COUNTY ASSESSOR 1400 NORTH 17th AVE. / d e DEN( 15145 RA FOR 21 TWOMBLYS 101 cREeL4r,CO 80631 DENVER AV FORT LUPTON 00000 PHONE(970)353-3845,EXT.365050 www.co.weld.co.us OWNER: VALERO DIAMOND METRO INC #4109 COLORADO CHRISTOPHER C. ROSAS LOG 4241 BURLESON COOKE L.L. P PARCEL 147106132016 711 LOUISANA STREET, STE. 1701 ACCOUNT P0012682 HOUSTON, TX 77002 YEAR 2007 Owner: VALERO DIAMOND METRO INC #4109 The appraised value of property is based on the appropriate consideration of the approaches to value required by law. The Assessor has determined that your property should be included in the following category(ies): Personal property - Everything that is not included under the term real property. Personal property is typically portable or movable items such as equipment, furniture, and freestanding appliances . If your concern is the amount of your property tax,local taxing authorities(county,city,fire protection,and other special districts)hold budget hearings in the fall. Please refer to your tax bill or ask your Assessor for a listing of these districts,and plan to attend these budget hearings. The Assessor has carefully studied all available information,giving particular attention to the specifics included on your protest,and has determined the valuation(s)assigned to your property. The reasons for this determination of value are: Your personal property has been valued in accordance with colorado law and instructions published by the state Division of Property Taxation. Other personal property, similar in nature, has been consistently valued using the same statutory methods . (n >- PETITIONER'S ASSESSOR'S VALUATION , PEIY CSSIFICATION ESTIMATE =c' Q OF VALUE ACTUAL VALUE ACTUAL VALUE )C PRIOR TO REVIEW AFTER REVIEW a!?! N Sri PERSla *OP° 223163 223163 CD ILI CJ o ^ TOTALS $ $ 223163 $ 223163 APPEAL DEADLINES: REAL PROPERTY—JULY 16,PERSONAL PROPERTY—JULY 20. If you disagree with the Assessor's decision,you have the right to appeal to the County Board of Equalization for further consideration. §3943-106(1)(a),C.R.S. TO PRESERVE YOUR APPEAL RIGHTS,YOU MAY BE REQUIRED TO PROVE THAT YOU FILED A TIMELY APPEAL; THEREFORE,WE RECOMMEND ALL CORRESPONDENCE BE MAILED WITH PROOF OF MAILING. 07/10/2007 By: Christopher M. Woodruff WELD COUNTY ASSESSOR DATE ADDITIONAL INFORMATION ON REVERSE SIDE NOD 207 62 87/07 YOU HAVE THE RIGHT TO APPEAL THE ASSESSOR' S DECISION The County Board of Equalization will sit to hear appeals beginning July 2 and continuing through August 3 for real property (land and buildings) and personal property (furnishings, machinery, and equipment). § 39-8-104 and § 39- 8-107(2), C.R.S. APPrktlrltOCED JRES If you choose to appeal the Assessor' s decision, mail or deliver one copy of this completed form to the County Board of Equalization. To preserve your right to appeal, your appeal must be POSTMARKED OR DELIVERED ON OR BEFORE JULY 16 FOR REAL PROPERTY, AND JULY 20 FOR PERSONAL PROPERTY. WELD COUNTY BOARD OF EQUALIZATION 915 10th Street, P.O. Box 758 Greeley, Colorado 80632 Telephone (970) 356-4000 Ext. 4225 NOTIFICAMMOFBIAIIINCi You will be notified of the time and place set for the hearing of your appeal. co ..CGUINTMSOARD-OREO11- OOfO S DETER INATIONi The County Board of Equalization must make a decision on your appeal and mail you a determination within five business days of that decision. The County Board must conclude its hearings and render decisions by August 3. TAXPA,Vglt'RTG 3TSTO"ReggI2T R PEKE'. r' If you are not satisfied with the County Board of Equalization' s decision you must file within thirty days of the County Board of Equalization' s written decision with ONE of the following: Board of Assessment Appeals (BAA): 1313 Sherman Street, Room 315 Denver, Colorado 80203 Telephone(303) 866-5880 www.dola.colorado.uov/baa District Court: 9th Avenue and 9th Street, P.O. Box C Greeley, Colorado 80632 Telephone (970) 356-4000, Ext. 4520 Arbitration: WELD COUNTY BOARD OF EQUALIZATION 915 10th Street, P.O. Box 758 Greeley, Colorado 80632 Telephone (970) 356-4000, Ext. 4225 If you do not receive a determination from the County Board of Equalization, contact the county board. If the county board is not going to mail a decision, you must file an appeal with the Board of Assessment Appeals by September 10th. TO PRESERVE YOUR APPEAL RIGHTS, YOU MUST PROVE YOU HAVE FILED A TIMELY APPEAL; THEREFORE, WE RECOMMEND ALL CORRESPONDENCE BE MAILED WITH PROOF OF MAILING. PETITION TO THE COUNTY BOARD OF EQUALIZATION In the space below, please explain why you disagree with the Assessor' s valuation. IN ACCORDANCE WITH § 39-8-106(1.5), C.R.S., IF YOUR APPEAL INVOLVES REAL PROPERTY, YOU MUST STATE YOUR OPINION OF VALUE IN TERMS OF A SPECIFIC DOLLAR AMOUNT. Attach additional documents as necessary. In support of the Petition to the County Board of Equalization of the denial by the County Assessor of the Written Letter of Objection and Protest; the Written Letter of Objection and Protest and all information submitted to the County Assessor is hereby adopted as the basis for the appeal to the County Board of Equalization. Petitioner requests that the County Board of Equalization examine this information and render its decision based on the written information submitted in support of Petitioners proposed valuations. Petitioners reserve the right to submit a ditional docu ents pricy to the hearing. Petitioners estimate of value in regard to Schedule No. P0012682 is$14,450. SICiNAIURE OF -III1ONER DME NOD 207 62 87/07 • VU IRO ERO Ad Valorem Tax T��ENERGY CORPORATION WELD COUNTY COMMISSIONERS June 27, 2007 2001 JUL -3 A q, 4l REEIVED Via First Class Mail C Mr. Christopher N. Woodruff Weld County Assessor 1400 N. 17th Avenue Greeley, Colorado 80631 RE: 2007 Letter of Objection and Protest; Letter of Representation. Dear Mr. Woodruff: The purpose of this letter is to provide notice to your office that the following individual and law firm has been retained to represent the taxpayers set forth in Exhibit "A" in regard to the letter of objection and protest filed with your office for year 2007: Christopher C. Rosas Colorado Bar No. 33018 BURLESON COOKE L.L.P. 711 Louisiana Street, Ste. 1701 Houston, Texas 77002 (Telephone): (713) 358-1700 (Toll Free Voice): (866) 652-1717 (Facsimile): (713) 358-1717 Please note in your records that copies of all notices or communications by the Weld County Assessor's Office or the Weld County Board of County Commissioners should also be mailed to this office do Christopher C. Rosas. Please feel free to contact me with any questions. Respectfully, ii),CAt. Arc& John Aranda JA cc: /Weld County Board of County Commissioners 915 Tenth Street Greeley, Colorado 80632 (00015108]) Exhibit "A" Taxpayers and Schedule Numbers Diamond Shamrock Stations, Inc. Schedule Numbers (PP): P0009071 095913300008; P0014846 096131416003; Valero Diamond Metro, Inc. Schedule Number (PP): P0012682 147106132016. -End- {00015108 I) BURLESON COOKE L.L.P. \ ATTORNEYS & ADVISORS Christopher C.Rosas Direct Dal 713-358-1712 Direct Fax 713-358-1717 rrora•radburic.oncookcCom www.burlooncooke con, July 16, 2007 Via CM/RRR No. 7005 2570 0000 7260 7550 Weld County Board of Equalization 915 10th Street, P.O. Box 758 Greeley, Colorado 80632 Re: 2007 Letter of Objection and Protest (PP); Petitions to County Board of Equalization. Dear Sir or Madam: Pursuant to C.R.S. § 39-8-106, we hereby submit the enclosed Petition to the County Board of Equalization appealing the decisions of the Weld County Assessor regarding the Letter of Objection and Protest submitted by Petitioner. Also enclosed are copies of working papers submitted to the Weld County Assessor in support of the Petitioner's proposed valuations. We respectfully request that the County Board of Equalization examine this information and render its decisions based upon the written information submitted by Petitioners. In the event the County Board of Equalization does not grant, in whole or in part, the appeal from the Weld County Assessor's denial for the property for which the appeal is being made, please note in your records that copies of decisions should be mailed to the undersigned. Respectfully, BURLESO COOKE L.L.P. 1 iliV c , anA....,_ Christopher C. Rosas CCR Enclosures {00015912.1} 711 Louisiana Street, Suite 1 701 • Houston, Texas 77002 Telephone: 713,358.1700 • Fax: 713.358.1717 Go BURLESON COOKE L.L.P. ATTORNEYS & ADVISORS Christopher C. Rosas Direct Dal 713-358-1712 Direct Fax 713.358-1 717 crow burlceoncrwkc rom WW W I,urlero,,cooke cool July 3, 2007 � y J nc 1 t re- r Via Hand Delivery r 7.1.o 1"1`i w can o Mr. Christopher N. Woodruff cc Weld County Assessor C D z, 1400 N. 17th Avenue C) 4, N-< Greeley, Colorado 80631 co RE: Letter of Objection and Protest (PP) Year 2007; Position Papers in Support of Proposed Valuations. Dear Mr. Woodruff: This letter is being submitted in support of the letter of objection and protest regarding personal property filed with your office for tax year 2007 for the taxpayers reflected in Exhibit "A". Taxpayers set forth in the body of these working papers, in part, their explanation in support of proposed valuations. Determination of Actual Value Underground fuel storage tanks ("UST") owned by these taxpayers in Weld County constitute a significant portion of taxpayers' personal property assessed by the Weld County Assessor. Taxpayers' business personal property must be assessed based on its actual value. Under Colorado law, actual value is synonymous with market value. Market value represents what a willing buyer would pay a willing seller under normal economic conditions. In other words, the most probable price for which the appraised property will sell in a competitive market under all conditions requisite to a fair sale. Although Colorado statutes require the application of the cost, market and income approaches to appraisal where applicable, the Constitutional mandate is to determine the property's actual value. As such, the ultimate determination must be what a willing buyer would pay a willing seller for the business personal property. According to the Division of Property Taxation ARL's, which the assessors are bound to comply with, the assessor must examine the "characteristics and condition of [a parcel of] property" to determine a "clear, current and detailed description of the subject property before estimating value." If circumstances exist under which the three (3) appraisal methods do not provide a clear basis for determining actual value, the assessor should look to all existing ;00015368.1) 711 Louisiana Street, Suite 1 701 . Houston, Texas 77002 Telephone: 713.358.1700 t Fax: 713.358.1717 • • information in an effort to ensure that its determination of actual value is accurate "to the extent which is equitably and practically possible." It is only by the examination and consideration of all information that the true nature and physical condition of the personal property may be determined. Based on the unique characteristics of a UST, the cost, market and income approaches, as employed by the Weld County Assessor's Office, do not provide an accurate basis for determining what a willing buyer would pay a willing seller. Based on the physical characteristics and regulatory requirements regarding UST's in Colorado, the value of a used UST as measured by the willing buyer-willing seller standard is virtually zero. There is no question that during the removal process the vast majority of UST's cannot maintain structural integrity and will disintegrate. Assuming for the purposes of argument that a used UST were to maintain its structural integrity upon removal, a hypothetical buyer must comply with federal and state regulations regarding the inspection, licensing and recertification of a UST prior to reuse. Furthermore, costs arising from the obligatory administrative, licensing and certification measures may be substantial, and would necessarily be taken into consideration by any willing buyer. These obligatory requirements are cost prohibitive and result in a practical situation in which no rational willing buyer will purchase a used UST and incur the loss and/or potential liability. The UST's owned by taxpayers are of various ages, but all have been subjected to petroleum substances for a period of time sufficient to result in the presence of residual amounts of these materials within the personal property itself. Any resale of a UST would entail a willing buyer expending significant amounts to remove, transport, test, recertify and relicense the UST being purchased. For example, Colorado Department of Labor and Employment, Division of Oil and Public Safety Storage Tank Regulations require the performance of numerous measures prior to the removal and/or replacement of a UST. Any party removing or replacing a UST must notify the Director of its intended action. Upon removal, that party must ensure that all residual fuel materials have been removed so that no more than 2.5 centimeters (one inch) of residue, or .3 percent by weight of the total capacity of the UST remain in the system. Further, the party must measure for the presence of a release from the UST where contamination is most likely to be present at the site. This process necessarily entails detailed and very costly excavation and testing of soils. Extensive records must be maintained by the seller demonstrating compliance with excavation and closure requirements under Colorado law. Finally the underground storage tank itself must be removed. A UST tank owner is obligated to perform these measures by state and/or federal law. These statutory obligations are by no means an all inclusive list, and the actual measures required may be much more burdensome. These measures result in significant transactional costs which are passed on to a buyer by the seller of a used UST. In an effort to deny the real world effect of these regulatory obligations upon the marketplace, the assessors have substituted cost for actual value. As a result, the assessors' valuation of taxpayer's business personal property does not reflect what a willing buyer would pay a willing seller for the property, and are thus, erroneous. The reality of the marketplace is that for much of taxpayer's business personal property, little to no market exists. As a result, any determination of actual value by the Weld County Assessor's Office which fails to consider the effect of these regulatory obligations and the physical characteristics of a used UST, and to allocate an appropriate deduction to the actual value, is erroneous based on the express (00015368.I) provisions of the Colorado Constitution, statutes, case law and Division of Property Taxation ARL's. Respectfully Submitted, art C. gen- Christopher C. Rosas CO Bar No.: 33018 BURLESON COOKE, L.L.P. 711 Louisiana St., Ste. 711 Houston, Texas 77002 (Voice): 713.358.1712 (Facsimile) 713.358.1717 Attorney for Taxpayer, Diamond Shamrock Stations, Inc. and Valero Diamond Metro, Inc. CCR Exhibit"A" (00015368.1) Exhibit "A" Taxpayers and Schedule Numbers Diamond Shamrock Stations, Inc. Schedule Numbers (PP): P0009071 095913300008; P0014846 096131416003; Valero Diamond Metro, Inc. Schedule Number (PP): P0012682 147106132016. -End- {00015108.1} 07/27/2007 FRI 11:39 FAX 713 358 1717 Burleson Cooke LLP 1®001/003 BURLESON COOKE L.L.R. ATTORNEYS & ADVISORS FACSIMILE TRANSMITTAL SHEET July 27,2007 TO7 FAX Nt:AMER: Clerk of the Board (970)352-0242 Weld County Board of Equalization FROM: Christopher C.Rosas Pages:3 • O URGENT O FOR REVIEW O PLEASE COMMENT O PLEASE.REPLY NOTES.'COMMF NTS. Re: 2007 (PP) Petitions to County Board of Equalization;Administrative Denials Please see attached. Please call Burleson Cooke L.L.P.(713)358-1700 if all pages are not received. CONFIDENTIALITY NOTE: The documents accompanying this facsimile transmission contain information which is confidential and/or legally privileged. The information is intcndcd only for the use of the individual or entity named above. If you arc not the intcndcd recipient, you arc hereby notified that any disclosure, copying, distribution or the taking of any action in reliance on the contents of this telecopied information is strictly prohibited. If you have received this facsimile in error,please immediately notify us by telephone to arrange for return of the original documents to us. 711 Louisiana Street,Suite 1701 (713)358-1700(Main) Houston,TX 77002 (713)358-1717(Fax) ur/cr/Luui rtu ll:ss rA3 /13 son tilt Burleson cooKe LLr IQ11uuc/Uus bBURLESON COOKE L.L.P. ....,,... . \__ ATTORNEYS & ADVISORS Christopher C.Ro,a3 Dhocc Dal 713.3ilt•17 t 2 1)iccc,Flu 713-35L 1717 cuev lwrirQ.UePot4e c e www.biulonocookexout July 27,2007 Via Facsimile(970)352-0242 • Weld County Board of Equalization Attn: Clerk to the Board 915 10th Street,P.O.Box 758 Greeley,Colorado 80632 Re: 2007(PP) Petitions to County Board of Equalization;Administrative Denials. Dear Clerk: The purpose of this letter is to request administrative denials of the Petitions to the Board of Equalization regarding the 2007 appeals of business personal property for the Petitioners and schedule numbers set forth in Exhibit "A" of this letter. Further rights to appeal, in accordance with state law will be preserved. Please feel free to contact me with any questions. Respectfully, BURLESON COOKE L.L.P. O -". . ( _A_,,....,...- Christoph r C. Rosas CCR Enclosures {00016328.1} 711 Louisiana Street.Suite 1701 Houston,Texas 77002 Telephone: 713.358.1700, Fax: 713.358.1717 07/27/2007 FRI 11:40 FAX 713 358 1717 Burleson Cooke LLY 4Q UUo/UU4 Exhibit"A" Taxpayers and Schedule Numbers Diamond Shamrock Stations, Inc. Schedule Numbers (PP): P0009071 095913300008; P0014846 096131416003; Valero Diamond Metro,Inc. Schedule Number(PP): P0012682 147106132016. -End- {00015108 I) tearl CLERK TO THE BOARD PHONE (970) 356-4000 EXT 4226 FAX: (970) 352-0242 WEBSITE: www.co.weld.co.us I 915 10TH STREET P.O. BOX 758 C. GREELEY, COLORADO 80632 COLORADO July 25, 2007 VALERO DIAMOND METRO INC #4109 AD VALOREM TAX DEPT PO BOX 690110 SAN ANTONIO TX 78269-0110 Parcel No.: 147106132016 Account No.: P0012682 Dear Petitioner(s): The Weld County Board of Equalization has set a date of August 2, 2007, at or about the hour of 4:40 PM,to hold a hearing on your valuation for assessment. This hearing will be held at the Weld County Department of Planning Services, Conference Room, 918 10th Street, Greeley, Colorado. You have a right to attend this hearing and present evidence in support of your petition. The Weld County Assessor or his designee will be present. The Board will make its decision on the basis of the record made at the aforementioned hearing, as well as your petition, so it would be in your interest to have a representative present. If you plan to be represented by an agent or an attorney at your hearing, prior to the hearing you shall provide, in writing to the Clerk to the Board's Office, an authorization for the agent or attorney to represent you. If you do not choose to attend this hearing, a decision will still be made by the Board by the close of business on August 3,2007, and mailed to you on or before August 10, 2007. Because of the volume of cases before the Board of Equalization, all cases shall be limited to 15 minutes. Also due to volume, cases cannot be rescheduled. It is imperative that you provide evidence to support your position. This may include evidence that similar homes in your area are valued less than yours or you are being assessed on improvements you do not have. Pleasenote: The fact that your valuation has increased cannot be your sole basis of appeal. Without documented evidence as indicated above, the Board will have no choice but to deny your appeal. If you wish to obtain the data supporting the Assessor's valuation of your property, please submit a written request directly to the Assessor's Office by fax(970)304-6433, or if you have questions, call (970) 353-3845. Upon receipt of your written request, the Assessor will notify you of the estimated cost of providing such information. Payment must be made prior to the Assessor providing such information,at which time the Assessor will make the data available within three(3) working days, subject to any confidentiality requirements. Please advise me if you decide not to keep your appointment as scheduled. If you need any additional information, please call me at your convenience. VALERO DIAMOND METRO INC#4109 - P0012682 Page 2 Very truly yours, BOARD OF EQUALIZATION Donal�a� 4 Clerk to the Board cc: Christopher Woodruff, Assessor CHRISTOPHER C. ROSAS BURLESON COOKE L.L.P 711 LOUISANA STREET, STE. 1701 HOUSTON TX 77002 Hello