Westinghouse Electric Corp. v. County of Los Angeles

In these 16 consolidated actions, we consider the right of appellants, taxpayers, to recover ad valorem personal property taxes paid without first pursuing their administrative remedies before the county board of equalization to reduce their assessments. We conclude that the facts which govern our action do not excuse appellants from their duty to exhaust administrative remedies; We accordingly affirm the trial court’s judgments for respondents.

Without first seeking administrative review before the county board of equalization, appellants filed their lawsuits to recover ad valorem taxes paid by them on business personal property located in the County of Los Angeles. The theory of the actions is that appellants’ property was taxed based upon a discriminatory assessment ratio, having been systematically valued at 50 percent of market value, whereas the average ratio of assessed to market value of other property subject to the ad valorem tax was 25 percent or less.

“Ordinarily a taxpayer seeking relief from an erroneous assessment [of ad valorem property tax] must exhaust available administrative remedies before resorting to the courts [citations]. Prior application to…