In a matter related to property tax assessments on 3 aircraft leased to appellant-real party in interest, judgment vacating respondent-appeals board's finding on apportionment is affirmed where: 1) even if the combined valuation of the aircraft by Nevada and California exceeded 100 percent of the value of the property, plaintiff-assessor-s apportionment formula was not arbitrary, but rather was rationally related to the opportunities, benefits, and protections afforded to appellant by state law; and 2) the trial court correctly concluded that defendant-appeals board's finding on the apportionment issue should be vacated.