Lilli Ann Corp. v. City & County of San Francisco

These two appeals, which have been ordered consolidated for the purposes of oral argument and decision, involve the validity of taxes paid to the City and County of San Francisco (the city) under protest by each of the plaintiff taxpayers. The taxes were assessed in 1967 as escaped assessments. (Rev. & Tax. Code, § 531 ) on the basis of reappraisals and reassessments of personal property for the years 1964, 1965 and 1966. The reappraisals and reassessments were made and the taxes were levied as a result of the so-called “Knoff mandate,” which followed a grand jury investigation of the assessment practices during the years in question. The background and the resulting escaped assessments have been the subject of other litigation. The taxpayers take the position that the convicted assessor, as did the legendaiy Robin Hood, took from the rich—the owners of personal property consisting of business inventories and equipment—and thereby relieved the poor—the owners of real estate, particularly owners of residential real property and household furnishings and equipment—from the burden of an equalized contribution to local ad valorem taxes. They assert that the city cannot assert…