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Tax Review Commission

MINUTES OF THE

TAX REVIEW COMMISSION

October 17, 1997 - 1:00 p.m. -- Room 405 State Capitol


Members Present:    
    Mr. Gary Cornia, Chair
    Mr. James B. Lee, Vice-chair
    Mr. Mark Buchi
    Mr. Robert M. Graham
    Sen. Lyle W. Hillyard
    Sen. George Mantes
    Ms. Carol McCormick
    Judge Jon Memmott
    Ms. Bonnie Miller
    Ms. Dorothy Owen
    Rep. John Valentine
    Mr. Ray Wood


    
Members Excused:

Mr. W. Val Oveson
Rep. Judy Ann Buffmire
    
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 1:10 p.m. and welcomed members of the Tax Review Commission ("TRC").

    Joe B. Pacheco, Commissioner, Utah State Tax Commission ("Tax Commission"), represented W. Val Oveson at this meeting.

     MOTION: Vice-Chair Lee moved to approve the minutes of the September 12, 1997 meeting. The motion passed unanimously. Sen. Hillyard, Ms. McCormick, Judge Memmott, and Rep. Valentine were absent for the vote.

2.     Property Tax Methodology
    a. Staff Reports     Linda Lemke, law clerk, presented an overview of background information on state statutes and constitutional provisions relating to the valuation of centrally assessed property and the taxation of intangibles. Her research included 16 states (states belonging to the Western States Association of Tax Administrators plus other states requested by the TRC), and revealed that treatment of intangibles and methodologies for valuation among the states is not consistent. Several states require the adoption of standard methodologies by the tax commission, while other states permit the use of specific methodologies for certain properties. She said that more detailed information will be presented in the November meeting.               

    b. Presentations by Taxpayers
    Judith G. Ross, Manager-Sales and Property Taxes, Delta Air Lines , said she was addressing the TRC as a representative of the Air Transportation Association ("ATA"). She presented the concerns of the ATA regarding the procedures used to value centrally assessed taxpayers in Utah. ATA carriers employ over 6700 persons statewide. She said that the airline industry experiences significant swings in profitability that are tied closely to economic business cycles and to other economic conditions such as oil markets, the stability of international politics, and the public's willingness to fly. Many of these conditions are beyond the industry's control. Ms. Ross illustrated the volatility of airline stock with the recent fall in Delta's stock prices by 7 percent following an announcement that earnings would be below analysts' expectations.

    Ms. Ross stated that she agreed with the testimony of presenters from other industries regarding the problems with the Utah Property Tax Division's ("the Division's") direct capitalization, stock and debt approaches, and treatment of intangibles. She said that Utah has consistently valued air carrier property higher than most other states. Consequently, Delta has appealed its Utah value every year since 1990.

    Ms. Ross said Utah's calculation of Delta's unit value for 1997 was $10.5 billion compared to the unit value given Delta by appraiser Thomas Tegarden of $5.35 billion. Chair Cornia requested a copy of Mr. Tegarden's appraisal. Ms. Ross agreed to provide a copy for the TRC. She outlined the primary differences between the Division's unit value and Mr. Tegarden's unit value. First, the Tegarden appraisal put little weight on the stock and debt approach and did not utilize a direct capitalization approach. Next, Mr. Tegarden's cost approach included a calculation of external and functional obsolescence, which was measured based on the difference between the projected achieved return and the required market return. Finally, Mr. Tegarden's appraisal put the most weight on a yield capitalization income approach. Ms. Ross stated that the unit value approach impounds intangibles. Trade name , goodwill, customer base, routes and slots, software, and combined expertise of work force are among the intangibles that impact Delta's value.

    Commissioner Pacheco disclosed his position as the presiding officer in the Delta Airlines case and raised the issue of conflict of interest. Chair Cornia requested that Mr. Pacheco remain in the meeting.

    Ms. Ross then discussed issues regarding leased aircraft. She said the value of leased aircraft is embedded in the income and stock and debt approaches through the valuation of the capitalized earnings and common equity. The Division treats leased aircraft as if owned, then adds back rent expense, computes a deduction for depreciation, and adjusts for taxes. Ms. Ross said this methodology fails to account for other factors which would be different if the aircraft had been purchased rather than leased.

    Ms. Ross outlined concerns with the direct capitalization approach. First, she commented that this methodology captures intangibles, especially stock prices; and second, the direct capitalization methodology cannot meet comparability requirements, and is therefore invalid. She said that although there is not a consensus in the airline industry as to the most appropriate valuation methodology, Delta is comfortable with a unit valuation which places primary weight on a properly applied yield capitalization model. Chair Cornia asked about comparable airlines to Delta. Ms. Ross said the comparability depends on the valuation model. Because the yield model considers the level of risk, it broadens the base of comparable companies. Chair Cornia then asked about the competition among airlines. Ms. Ross discussed competition and said that Delta targets the business traveler. Vice-chair Lee asked if methodology should be required in statute. Ms. Ross replied that methodology issues should be remedied through administrative practice and policy.

    Darrell Bell, AT&T Wireless, and Skip Cornett, U S West New Vector Group, submitted to the TRC a document titled "Utah Tax Commission Wireless Presentation." Mr. Cornett said that both AT&T Wireless and U S West New Vector Group have three years of appeals outstanding in Utah and no appeals in other states. Also, he commented that Utah has the highest assessed values as a percent of property costs than any other state. Mr. Bell said problems with valuation methodologies include: (1) divergence in indicators; (2) lien date; (3) capitalization rate; and (4) no removal of intangibles. He said that growth should be tied to the lien date because assets are valued and assessed that are not in existence at the lien date. He said the industry growth will be shared with at least six carriers in Salt Lake City versus two carriers currently sharing the market. Mr. Bell compared Utah's income indicator methodology and yield capitalization rates to other states in which AT&T Wireless operates. He said the income approach fails to remove intangibles from the income stream. Mr. Bell listed the FCC license, customer list, sales distribution agreements, trade name, assembled work force, favorable lease sites, and goodwill as intangibles in the wireless industry. Vice-chair Lee asked if it is possible to place a value on these intangibles.

    Mr.Bell said for the most part there is no cost basis for these assets. Commissioner Pacheco said that intangible items can be identified by valuing them on the books for purchase. Mr. Cornett said that process requires too much detail for an appraisal.

    Mr. Cornett summarized the presentation and stated that the wireless industry should be treated like any other competitive commercial business. He said that cellular transmission is comparable to radio and television broadcast which are not centrally assessed. He noted that Kansas and Oklahoma have ruled that cellular be locally assessed. He said that regardless of whether wireless is centrally or locally assessed, the cost approach to valuation is the most appropriate methodology because it does not capture intangibles. Mr. Wood asked if taxing intangibles would simplify the valuation. Mr. Cornett said it would require identifying intangibles and then arriving at a fair market value. Mr. Wood then asked if not taxing

intangibles places companies with a larger number of intangible assets at a competitive advantage. Mr. Cornett replied that much of the value is speculation. Chair Cornia said that the income approach includes speculation. Mr. Cornett said the income approach values current income or expectations of future income on the assets that exist.

    Glen Stevens, Property Tax, Questar Pipeline Co., reviewed the handout "Tax Review Commission, State of Utah, October 17, 1997" which lists the companies used as comparables by the Division in the valuation of Questar Pipeline. He highlighted the differences between the companies and said he does not know of a company that has high enough comparability to allow the use of direct capitalization methodology to value Questar Pipeline. He said that the ratio derived from the average of any comparable improperly imputes the market's perception of its characteristics to the subject company. He reported that his informal survey of 1997 appeals filed by centrally assessed utilities showed Utah second in number of appeals to California. Vice-chair Lee asked about including language in statute requiring specific methodologies for valuing each industry. Mr. Stevens said a requirement by statute does not provide flexibility as changes occur in the industries. Chair Cornia asked if Mr. Stevens would support a different method of taxation other than the property tax. Mr. Stevens said he prefers the property tax because it should assess all businesses equally, at 100 percent of fair market value.

    c. Information from Counties
    Bill Thomas Peters, Attorney for the Utah Association of Counties, distributed to the TRC the report "Initial Report of The Utah Association of Counties to The Tax Review Commission, Comparing Property Taxation Laws and Valuation in Other States." This report presents preliminary findings on the valuation practices of Arizona, California, Montana, Oregon, Colorado, Wisconsin, and Oklahoma. He stated that because there is little uniformity among states in tax valuation, comparisons of state values are unreliable. Mr. Peters noted that the tax value assigned to a property is a combination of state constitution, statute, and administrative rule; but, items such as the assessor's budget, staff size, financial expertise, or the political profile of the taxpayer often play as large a role in the value assigned by a state assessor as any legal requirement. Each state has unique laws resulting from administrative, state, and federal court decisions.

    Mr. Peters outlined his preliminary findings on the valuation practices of other states as follows:
    1.     There is little uniformity among the states in assessment practice.
    2.     Several states tax "intangibles," i.e., Colorado, Montana, Oregon, and Arizona. Others do not. Of those states that do not tax intangibles, some believe that the value of tangible property is influenced or enhanced by the existence of intangibles.
    3.     In most states polled, utilities and railroads are centrally assessed; in at least one state (Texas), these properties are locally assessed.
    4.     Of the states polled, a majority accept fair market value as their valuation standard.
    5.     In a majority of states, the determination of fair market value is a question of fact and appraisal judgment; in only a few states is valuation methodology established by written policy, rule, or statute (e.g., Arizona, California and New Mexico).
    6.     Assessment ratios vary among the states; some rely on 100 percent of fair value, others rely on various ratios for property classifications, e.g., utilities at 27% of fair value, telecommunications at 25% of fair value.
    7.     The taxable unit that is subject to assessment varies among the states. For example, several states do not include leased property in valuing property.
    8.     A majority of states prepare and consider a stock and debt indicator.
    9.     Several states prepare and consider a direct capitalization of income as an indicator of value, but applications vary.
    10.     There is no uniform "weighting" by the states of the various indicators of value.
    11.     Treatment of deferred federal income taxes varies among the states, some deduct it from the cost approach, several do not.
    12.     In the past, review of other state valuation practices has revealed various errors in application and practice.

    Mr. Peters also discussed the non-legal considerations when reviewing values from other states. He concluded that a comparison of the values placed on a property by other states is a flawed method to determine whether Utah has valued property at the constitutional fair market value standard. Also, any comparison of the valuation methods of other states should be limited to a clearly defined group of units of comparison that include a complete consideration of non- legal factors.

    Mr. Peters stated that the Utah Constitution's standards require more than a simple comparison of other state's values. The Constitution requires equity and uniformity. He then reviewed information regarding: (1) Utah's value of Union Pacific Railroad for tax year 1994 as compared to values in Washington, Oregon, Montana, California, Kansas, Texas, Oklahoma, Colorado, and Illinois ; (2) an 11 year history of valuation and assessment disputes between Union Pacific Railroad, the state of Utah, and its counties; (3) court cases and Tax Commission decisions; and (4) the position of the Division.

    Vice-chair Lee asked if the process used by the Division is satisfactory. Mr. Peters said that the back-log of cases is the main problem with the process. Vice-chair Lee commented that the appeals procedure needs to be streamlined. Mr. Peters said by statute there is now a two year limit on the Tax Commission for adjudicating appeals.

    Mr. Buchi said the TRC needs to understand the law regarding intangibles. Mr. Peters agreed and stated that in his opinion the Tax Commission confused "intangible property" with "intangibles." He feels that intangible property can be separated, identified, and sold. Mr. Peters also said if intangibles are stripped from centrally assessed properties, they must be stripped

from locally assessed properties as well. Mr. Buchi read the statute regarding the taxation of intangibles and asked if the Legislature has provided for the taxation of intangibles. Mr. Peters said that the Legislature provided that intangible property should not be taxed; however, in his opinion, the Tax Commission misinterpreted the statute. Chair Cornia urged the TRC members to read "UNION PACIFIC R. CO. V. STATE TAX COM'N OF UTAH" included in Tab C of Mr. Peters' handout.

13.     Federal Tax Reform and Its Impact on Utah
    
This item was not discussed.
    
14.     Other Business

    a. Work of Consultant
    Chair Cornia stated that the TRC has entered into a contract with Larry Walters, Professor of Public Policy and Policy Analysis, BYU; Michael Pinegar, Professor of Finance, BYU; and Jim Schallheim, Professor of Finance, University of Utah. They will present a report to the TRC at the next meeting. Chair Cornia encouraged the Tax Commission, attorneys from agencies, and representatives from companies to attend, and to provide input to the consultants. Chair Cornia asked staff to provide a list of questions that the TRC requested the consultants to address.
             b. Future Meetings
    The next meeting of the TRC was scheduled for November 25, 1997 from 9:00 a.m.- 4:00 p.m. A meeting was also tentatively scheduled for December 12, 1997 at 1:00 p.m.

    Mr. Wood distributed articles "Extracting the Value of Intangible Assets from the Unit Assessment Method" and "Ad Valorem Taxation of Cable Television Intangibles: The Search for the Holy Grail."

5.    Adjournment--

     MOTION: Sen. Hillyard moved to adjourn the meeting at 5:05 p.m. The motion passed unanimously.



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