TAXATION ‑- BRIDGE

TAXATION ‑- BRIDGE

1951 property taxes on the Hood River-White Salmon Bridge are valid, such bridge not being entitled to exemption under chapter 224, Laws of 1949 because the State of Oregon has in the same year taxed a bridge owned by the State of Washington.

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                                                                    July 30, 1951

Honorable Thurman E. Ward
Prosecuting Attorney
Klickitat County
Goldendale, Washington                                                                                                                Cite as:  AGO 51-53 No. 95

Dear Sir:

            We have your request for our opinion on the following question:

            Are 1951 property taxes levied by Klickitat County properly due upon the Hood River-White Salmon Bridge, which bridge is owned by the Port of Hood River, an Oregon municipal corporation?

            Our conclusion is:

            1951 property taxes on the Hood River-White Salmon Bridge are valid, such bridge not being entitled to exemption under chapter 224, Laws of 1949 because the State of Oregon has in the same year taxed a bridge owned by the State of Washington.

                                                                     ANALYSIS

            Klickitat County has apparently levied taxes upon the portion of the Hood River-White Salmon Bridge which lies within the State of Washington.  This bridge has been owned by the Port of Hood River, an Oregon municipal corporation, since December 12, 1950.  The reason for your question is undoubtedly chapter 224, Laws of 1949 (section 11111-12 Rem. Supp. 1949), which, in part, reads as follows:

             [[Orig. Op. Page 2]]

            "Any bridge * * * over rivers * * * forming interstate boundaries * * * being operated by any foreign state * * * county, city, or other municipality of such foreign state, shall be exempt from all property and other taxes in the State of Washington,if the foreign state exempts from all taxation any bridge or bridges constructed or acquired and being operated by the State of Washington or any county, city or other municipality thereof."  (Emphasis added.)

            Paraphrased, Washington property taxes will not be levied upon a bridge owned by a foreign state (such as the Hood River-White Salmon Bridge in this case) in any given year if the foreign state does not tax in the same year bridges operated by the State of Washington or a political subdivision thereof.

            We have found that the State of Oregon did tax, in the year 1951, a bridge operated by the State of Washington, viz., the Longview Bridge.  Therefore, the foreign state having taxed a state‑operated bridge, the Hood River-White Salmon Bridge is not entitled to exemption from taxation in the year 1951.

Very truly yours,

SMITH TROY
Attorney General

WILLIAM G. JENKINS
Assistant Attorney General