Chapter Tax 6

Tax 6.50(2)(g)2.b. b. Sale of the debt and equity interest of the subject or comparable enterprise as a proxy for the market value of the property presented on the balance sheet. This indicator is commonly referred to in appraisal and valuation literature as the stock and debt indicator.

Tax 6.50(2)(g)3. 3. The method whereby the investment expenditure required to purchase the anticipated future benefits resulting from the operation of the property is estimated and which is commonly referred to in appraisal and valuation literature as the capitalized income method. Indicators of value within the capitalized income method include:

Tax 6.50(2)(g)3.a. a. The capitalization of the estimated future income to the present owner or to a prospective purchaser. The estimated future income is that income which remains after book depreciation and federal tax expenses actually paid have been subtracted.

Tax 6.50(2)(g)3.b. b. The discounted or the present value of the estimated future cash flow to the present owner or to a prospective purchaser. The estimated future cash flow is that cash flow which remains after the asset replacement expenditures and the federal income taxes paid have been subtracted.

Tax 6.50(2)(h) (h) “Unit valuation” is the appraisal as a whole of an integrated property operated as a going concern without any reference to the value of its component parts.

Tax 6.50(3) (3) Derivation of indicators of value. In principle each recognized appraisal method shall as near as possible follow a logic which is separate and unique and the department will attempt to apply the various appraisal methods in a manner which maximizes the uniqueness of each method.

Tax 6.50(4) (4) Cost indicators of value.

Tax 6.50(4)(a) (a) In determining cost indicators, the department may consider 4 kinds of cost described as follows:

Tax 6.50(4)(a)1. 1. Historical cost of the property when first put in service;

Tax 6.50(4)(a)2. 2. Original cost of the property to the present owner;

Tax 6.50(4)(a)3. 3. Reproduction cost to currently reproduce the property; and

Tax 6.50(4)(a)4. 4. Replacement cost to currently replace the property with its functional equivalent.

Tax 6.50(4)(b) (b) The department shall make adequate and reasonable allowances for loss of value due to all causes including physical depreciation, functional and economic obsolescence, regulatory required write-offs and utility plant acquisition adjustments. The cost indicator for regulated public utilities shall recognize that an asset’s value generally is limited by its value for ratemaking purposes. The cost indicator shall include construction work in-progress regardless of the treatment for ratemaking purposes.

Tax 6.50(5) (5) Stock and debt indicators of value.

Tax 6.50(5)(a) (a) Stock and debt indicators are determined by the application of the general financial appraisal principle that the market value of the debt and equity interests of the enterprise are equal to the market value of the assets presented on the balance sheet. Stock and debt indicators determine the value of a company’s assets by appraising the value of the shareholders’ equity and liabilities of the company, such as current liabilities, long-term debt, reserves and deferred credits. Appropriate reductions shall be made for nonoperating property of the company. The department may consider the following ratios to eliminate nonoperating properties:

Tax 6.50(5)(a)1. 1. Nonoperating book value to total book value, or

Tax 6.50(5)(a)2. 2. Nonoperating income to total income.

Tax 6.50(5)(a)3. 3. Nonoperating market value to total market value.

Tax 6.50(5)(b) (b) The department shall also make required adjustments for nontaxable properties as set forth in sub. (4).

Tax 6.50(6) (6) Capitalized income indicators of value. Capitalized income indicators are determined by the application of the general appraisal principle that the full market value of operating property is the present worth of anticipated future benefits to be derived from ownership of the property. Future benefits are the summation of the positive and negative cash flows which a fully informed person is warranted in assuming will be produced by operations of the property as a going concern. The department shall reflect earnings limitations imposed upon regulated utilities in this determination.

Tax 6.50(7) (7) Correlations of indicators of value.

Tax 6.50(7)(a) (a) The validity of a determination of value may be measured against the supporting evidence and documented data from which the determination of value was derived. Accordingly the department shall consider and weigh, in its best judgment any or all available indicators of full market value enumerated in sub. (2) (g) 1. to 3. In this correlation process it shall consider the following:

Tax 6.50(7)(a)1. 1. The speculative nature of estimates used in developing the indicators of value and the degree of reliability of each of the indicators of value.

Tax 6.50(7)(a)2. 2. The consistency of weighting indicators of value from year to year.

Tax 6.50(7)(a)3. 3. Uniformity of assessments within taxpayer classifications.

Tax 6.50(7)(a)4. 4. Buyer’s and seller’s viewpoints.

Tax 6.50(7)(a)5. 5. The reasonableness of the correlated full value market estimate when compared to:

Tax 6.50(7)(a)5.a. a. Actual sales of comparable properties in an arm’s-length transaction between independent parties;

Tax 6.50(7)(a)5.b. b. Rate base;

Tax 6.50(7)(a)5.c. c. Other states’ correlated estimates of full market value of the same company adjusted for differences in state law;

Tax 6.50(7)(a)5.d. d. Net salvage value;

Tax 6.50(7)(a)5.e. e. Additional evidence of full market value submitted by the company or the department;

Tax 6.50(7)(a)5.f. f. Value asserted in prospectus; and

Tax 6.50(7)(a)5.g. g. All other facts obtainable bearing on the value of the property collectively.

Tax 6.50(7)(b) (b) In the case of regulated utilities, a sale is comparable only if there is the sale of an entire operation capable of functioning independently and the parties thereto are subject to regulatory policies similar to those of Wisconsin.

Tax 6.50(8) (8) Requests for documentation. Upon written request the department shall provide to the company copies of its computational worksheets used in determining full market value.

Tax 6.50(9) (9) Correction of errors. Errors which are agreed to be palpable or computational and which are discovered after issuance of the assessment shall be adjusted by the department in the next subsequent assessment year and the department shall provide the company with evidence of such adjustment.

Tax 6.50 Note Note: This section interprets s. 76.07 (5), Stats.

Tax 6.50 History History: Cr. Register, November, 1983, No. 335, eff. 12-1-83; CR 13-037: am. (4) (b) Register February 2014 No. 698, eff. 3-1-14.