Bade V. Drachman

Plaintiffs Drachman are the owners of commercial real property and the improvements thereon and plaintiff Campbell Plaza Co. is the lessee of this property. The improvements consist of a shopping center, constructed in 1960. In 1963, the Pima County Assessor assessed for tax purposes all and in Pima County not subject to assessment by the State Tax Commission at 12 1/2 per cent of full cash value as determined by the Assessor while all realty improvements were assessed at 23 per cent of full cash value. The property which is the subject of this litigation was assessed for tax purposes in 1963 in accordance with these percentages. To determine the assessed value of improvements, the Assessor's method was to apply the percentage of 23 per cent to the actual cost of construction less a depreciation factor of 2 per cent per annum.