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Tax Review Commission

MINUTES OF THE

TAX REVIEW COMMISSION

August 15, 1997 - 1:00 p.m. -- Room 405 State Capitol


Members Present:    
    Mr. Gary Cornia, Chair
    Mr. James B. Lee, Vice-chair
    Mr. Mark Buchi
    Rep. Judy Ann Buffmire
    Ms. Carol McCormick
    Ms. Bonnie Miller
    Ms. Dorothy Owen
    Mr. W.Val Oveson    
    Rep. John Valentine
    Mr. Ray Wood



Members Absent:
Sen. Lyle W. Hillyard    
Sen. E. George Mantes
Judge Jon Memmott
        
Members Excused:

Mr. Robert M. Graham
    
Staff Present:
    Mr. Bill Asplund
     Executive Director
    Ms. Rebecca L. Rockwell
     Associate General Counsel
    Ms. L. Kaye Clark
     Secretary


Note:    A list of others present and a copy of materials distributed in the meeting are on file in the Office of Legislative Research and General Counsel.
    
1.    Call to Order and Approval of Minutes -- Chair Cornia called the meeting to order at 1:20 p.m. and welcomed members of the Tax Review Commission ("TRC"). He introduced Kaye Clark as the new secretary and asked staff to draft a letter from the TRC thanking Karen Mecham for her years of service as secretary of the TRC.

    Chair Cornia announced that Charlie Johnson has left the governor's office. Chair Cornia moved that staff draft a letter on behalf of the TRC expressing appreciation for Mr. Johnson's work.

     MOTION: Chair Lee moved to approve the minutes of the July 11, 1997 meeting. The motion passed unanimously.

2.     Property Tax Methodology

    Mr. Robert Strong, Property Tax Manager, PacifiCorp, distributed copies of his presentation and reviewed his background and perspective. He has been involved in the valuation and taxation of centrally assessed properties for almost 21 years, was a utility appraiser for the State of Idaho, and deals with centrally assessed property in ten states. He said that this allows him to view how other states have dealt with the same issues Utah is facing.

    Mr. Strong said he would report on the following topics: (1) methodologies and procedures of the Property Tax Division (the "Division"), (2) intangibles, and (3) comparing Utah's centrally assessed values to values in other states.

    (1)     Methodologies and Procedures - Property Tax Division - Mr. Strong said that reliance on stock prices and the inclusion of intangibles are at the core of a majority of the valuation issues concerning centrally assessed properties in Utah. The Division uses a variation of the direct capitalization method in which both the income indicator and the stock and debt indicator are driven by stock prices. The Utah Constitution generally requires that all tangible property be taxed. However, he said, stock prices are not real tangible property, are subject to market speculation, and represent fractional interests in a business. He said the use of stock prices is inappropriate because it is an attempt to relate the value and prices of very liquid securities traded in the stock market to real tangible property in Utah.

    Mr. Strong referred to an article titled "On the Stock and Debt Approach to Valuation of Utility Property" by Hal B. Heaton in his discussion on the direct capitalization method.

    Mr. Strong then discussed weightings and correlation. Mr. Strong explained that the Division must correlate its various individual indicators of value under different valuation methodologies into a single value conclusion. To obtain a value conclusion, the Division applies weightings to the individual indicators of value. He said that currently the Division does not disclose its weightings of the individual indicators of value. This requires companies, the State Tax Commission (the "Commission"), and the counties to speculate as to how they got from their individual indicators of value to the precise value conclusion. He said that taxpayers want full disclosure from the Division regarding its methodologies, policies, and procedures.

    Mr. Strong next discussed the Division's tax policy versus the Commission's tax policy. He said this is perhaps the most difficult area to discuss because it is based on perception. It is his perception that the Division no longer believes in or supports the Commission's or the court's decisions. He said the Division's actions border on setting their own tax policy rather than exercising appropriate appraisal judgment.

    (2) Intangibles - Mr. Strong said that at issue is the difference between a business' real tangible assets and the value of the business, known as the going concern value. Another issue is that of equity with commercial taxpayers assessed by the county assessor. Mr. Strong said that intangibles are taxed under the income tax.
    
    (3) Comparison to other states - Mr. Strong said that Glen Stevens would present most of the data comparing Utah to other states. However, he stated that of the ten states in which PacifiCorp has electric operations, Utah ranks second highest behind Washington in all

combined taxes. He said he will prepare a chart showing how Utah compares to these other states.

    Chair Cornia asked Mr. Strong to include on the chart the methodology used by each state. Mr. Strong agreed and said he would also include the property tax per dollar of investment.

    Chair Cornia asked if Mr. Strong would recommend that the Legislature prescribe weightings for purposes of valuation correlations. He recommended that the Division disclose weightings rather than prescribing the weightings statutorily. Mr. Buchi then asked if Mr. Strong would recommend legislation as the solution to the intangibles issue. Mr. Strong said he would rather have the Commission set clear rules and regulations.

    Chair Cornia asked Mr. Strong to prepare a brief report explaining why he feels the Division's policies are inappropriate.

    Rep. Valentine said there is a need to define the issues of valuation methodology more clearly. He said that it is difficult to understand the points of disagreement between the county assessors and the Commission.

    Chair Cornia asked Mr. Eyre and Mr. Strong to prepare a report showing their points on each issue. Chair Cornia requested that each address their valuation estimate under various methodologies including: (1) cost; (2) stock and debt; (3) discounted cash flow; and (4) direct capitalization. Rep. Valentine said that information would be very helpful.

    Rep. Short asked Mr. Strong what method he feels is the most equitable. Mr. Strong replied that a property tax applied fairly among all classes of property is reasonable.

    Mr. Reed Searle, Intermountain Power Agency, said disclosure of weightings and a uniform application of the process would be an improvement over the current practice. He said that he would like to know the reasons behind any adjustments to the correlation factors.

    Sen. Stephenson said that residential property tax valuation information is public and asked if similar information about centrally assessed properties is confidential. Mr. Strong said that all similar companies should know how they are weighted. Mr. Strong stated that it is more important, however, for the Division to disclose to a company information regarding the company's own valuation.

    Mr. Lee asked Mr. Strong what he feels is the best method to arrive at fair market value. Mr. Strong advocated the use of the cash flow yield model to arrive at the income indicator rather than the direct capitalization or stock and debt methodologies.

    Rep. Short asked Mr. Eyre if the Division has ever changed weightings to achieve a predetermined value. Mr. Eyre said he knows of no case where that has been done. Mr. Eyre said the correlation process is judgment and that value cannot be determined to the dollar.

     Glen Stevens, Questar, said the focus of his presentation was to provide additional facts concerning the WilTel intangible issue and centrally assessed appeals. He made the following arguments: (1) the WilTel decision did not create a crisis; (2) centrally assessed taxpayers are carrying their tax load; and (3) centrally assessed properties in Utah are overvalued when compared to other states.

    Mr. Stevens claimed that the WilTel decision did not create a crisis. He said the percentage of the Division's assessments in dispute has decreased in recent years. This is attributable to Commission rulings requiring the Division to modify their methodology. WilTel has not changed the reasons why centrally assessed taxpayers have appealed. Intangible value imputed into centrally assessed valuations by the use of and reliance on stock prices has been an issue since the Division changed its methodology to capture intangibles.

    Mr. Stevens said that centrally assessed property taxpayers are carrying their load. There has been a definite shift in the overall property tax burden. Homeowners received exemptions which creates a shift in the tax base to centrally assessed taxpayers. Mr. Strong commented that centrally assessed tax payers have been forced to assume an artificially greater share of the total tax burden through income, sales, property, and franchise taxes.

     Mr. Stevens claimed that centrally assessed property is overvalued. He said that because of the Division's use of the direct capitalization methodology and reliance on the stock and debt indicator, the Division has consistently calculated higher system values than other states in which PacifiCorp and Questar Pipeline operate. He said these methods overstate value because they impute intangible value included in stock prices into assessments. There would be fewer appeals if centrally assessed properties were valued and taxed at the legislated level of 100 percent of fair market value of the tangible real and personal property.

    Chair Lee asked what changes need to be made in statute to arrive at fair market value. Mr. Stevens replied that the Legislature should state that methodologies (such as direct capitalization and stock and debt) that impute intangible value into assessments may not be used.

    Rep. Buffmire commented that it is too soon to tell if Wiltel will create a crisis. She feels that there may be a crisis and we need to be prepared for that possibility.

    Chair Cornia requested that Mr. Stevens and Mr. Strong provide the following information to the TRC:
    1.    A comparison of assessed and allocated values and the taxes paid in other states in which the company operates.

    2.    Describe the differences in values calculated by the Division, the counties, and the taxpayers. Demonstrate whether the differences in value are attributable to the various valuation methods employed (i.e. stock and debt, direct cap, yield cap, discounted cash flow) or whether the differences arise in the correlation of the values calculated under different valuation methods.

    3.    Explain why a cost regulated utility has intangibles. What are the comparisons with unregulated utilities?

    4.    The WilTel decision requires the taxpayer to identify intangibles. What are your company's intangibles and how do you propose identifying their separate values? Are they currently subject to property taxation? Should they be taxed in light of WilTel?

    5.    Has the system become too complicated? Is there some other process or some other tax that would generate the revenues fairly and with less administrative and compliance difficulties?

    Chair Cornia also asked the Association of Counties and the Division to respond to these issues.
    
2.     Property Tax Methodology


     Utah Association of Counties _ Brent Gardner, Executive Director, Utah Association of Counties, said he was asked to comment on procedural issues at the Commission, assessment methodology on centrally assessed properties, and intangibles.

    Mr. Gardner referred to an audit titled "1995 Audit of the Utah State Tax Commission" in his discussion of procedural issues. He said that this audit (pages 7 and 15) makes recommendations for an increased litigation budget for the Commission to be able to meet the time frames prescribed for appeals.

    Chair Cornia asked if the counties present an appraisal when they make an appeal to the Commission. Mr. Eckhardt A. Prawitt, Utah Association of Counties, said that it is not required. However, he feels that a reason for appealing should be required.

    Mr. Gardner raised the issue of proposed legislation separating the administrative functions from the adjudicatve functions of the Commission. He said that although this bill did not pass, he feels it is still an issue that needs to be addressed.

    Mr. Gardner said the issue concerning methodology is not whether the methodology overvalues the property, but whose judgment should be used in applying the methodology. He said that the courts and the Commission have upheld the methodology being used in Utah. The disputes are over judgments in applying the methodology. He said that fairness between Utah and other states is not as relevant as fairness within the state.

    Chair Cornia felt that fairness between states is an important issue and requested a brief report from Bill Thomas Peters showing comparisons to support Mr. Gardner's statement about the issue of fairness between states. Mr. Gardner agreed to produce that information for the TRC.

    Mr. Gardner distributed a handout titled "Comparison of Property & Severance Taxes on Oil and Gas Property/Production." This handout shows that the amount of property tax and severance tax on oil and gas property and production track very closely. Therefore, he made a proposal to replace the property tax with the severance tax, arguing that the severance tax is less expensive and less complicated to calculate. He said that the oil and gas industry was not in favor of this change.

    Mr. Prawitt said that according to the universal valuation principle, a property should always be valued at its highest and best use. He said that the Division has determined that the highest and best use of property is as an integrated unit system. He said that this includes the intangibles.

    Mr. Prawitt said that it is his thesis that an entire property consists of nothing but intangibles. He explained that all costs are intangible. For example, the value of land is based on its scarcity and the availability of services, which are intangible. Mr. Prawitt claimed that the real question is which intangibles will be taxed and which will be exempt. He feels that only intangible property which is capable of ownership is exempt under the law. Mr. Prawitt referred to an article by Jim Bonbright in his discussion on intangibles.

    Mr Prawitt said that comparisons between states are irrelevant because other states are simply taxing a different set of intangibles. This is due to the fact that they have defined a unit differently than Utah. He feels that the relevant comparison is between centrally and locally assessed property in Utah. Both should have the same exemptions.

    Chair Cornia asked Mr. Prawitt to provide the citation to the Jim Bonbright article and a copy of his presentation for the TRC. Chair Cornia asked Mr. Prawitt to respond to the request for information given to the other speakers, using a replacement cost methodology. Mr. Prawitt said that the cost indicator will not get to the fair market value.

    Chair Cornia asked Mr. Prawitt if he would use replacement cost in cost regulated utlities. He said that he uses replacement cost as an indicator.

    Mr. Oveson commented that H.B. 129 put a two-year time limit on the Commission for adjudicating centrally assessed appeals and therefore there is no need to increase the budget for litigation.

    Chair Cornia asked staff to mail copies of the 1995 audit to the TRC members.

    Mr. Buchi asked Mr. Gardner to provide a county by county list of who uses Marshall and Swift as a basis for determining cost. Mr. Gardner agreed to do so. Chair Cornia asked the Division to provide the TRC members with a summary of Marshall and Swift. Chair Cornia asked Mr. Buchi to provide a copy to staff of Hal Heaton's paper that was presented in Wichita.
    
4.    Other Business--The next meeting of the TRC will be held on Friday, September 12, 1997, at 1:00 p.m. in room 405.

    Sen. Stephenson reported that the National Conference of State Legislators and the National Tax Association enacted resolutions regarding taxing the internet. He said Congress is also discussing this issue. He commented that the National Conference of State Legislators and the National Tax Association are very interested in the outcome of the national study on the taxation of telecommunications chaired by Gary Cornia.

5.    Adjournment--

     MOTION: Vice-chair Lee moved to adjourn the meeting at 4:55 p.m. The motion passed unanimously. Mr. Wood and Ms. Owen were absent for the vote.




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