GLIDDEN COMPANY v. COUNTY OF ALAMEDA (1970)

In its petition for rehearing the taxpayer urges that the handbook referred to in the opinion—‘The Appraisal of Equipment and Inventory’ (June 1961)—and a second handbook ‘General Appraisal Manual’ (June 1964) demonstrate that the assessor's full cash value and the board's full cash value must be identical because the methods of valuation prescribed are the same. The board is authorized and directed to prescribe rules and regulations to govern local boards of equalization when equalizing, and assessors when assessing, and also to prepare and issue instructions to assessors designed to promote uniformity throughout the state. (Gov.Code, s 15606, subds. (c) and (e). See Gallagher v. Boller (1964) 231 Cal.App.2d 482, 488—489, 41 Cal.Rptr. 880; and People ex rel. Mosk v. City of Santa Barbara (1961) 192 Cal.App.2d 342, 348—349, 13 Cal.Rptr. 423.) There is evidence to show that the board followed the assessment practices set forth in those handbooks. There is no specific testimony to show that the assessor followed them. Even if it be assumed that he did, it would be enshrining a hypothesis to the exclusion of reality to conclude that two persons applying the same guidelines would arrive at the same absolute figure. The opinion points out that the standards leave room for reasonable differences of opinion. The lacuna in the taxpayer's proof is not cured by reference to the handbooks.

Rehearing denied.

PER CURIAM.