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Stone Brewing Co. is challenging the first local real estate tax assessment on its new brewery in Fulton, writing in a letter to the Richmond assessor’s office that it will pay the $220,000 bill, but only under protest.

“That notification letter is the first thing they have to do before appealing to a court,” said city assessor Jim Hester.

As currently assessed, Stone would be required to pay an estimated $12.2 million in real estate taxes through 2040. Stone is pushing to have that reduced to $3.1 million.

If Stone isn’t successful, the city could be on the hook to rebate the $9.1 million difference between the two figures under a clause in an agreement between the city and the San Diego-based brewer.

At issue is how Stone would be assessed real estate taxes while it rents the property from the Richmond Economic Development Authority, which built the brewery for the company using $23 million in bonds issued by the city as part of the economic development package used to entice the brewer to locate here.