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This action was brought by several persons owning homes in that part of Los Angeles lmown as Brent-wood to recover property taxes paid under protest for the tax year 1960-61. Plaintiffs’ contention is that the assessment made by the county assessor as of the first Monday in March 1960 increased the assessments on land in the Brentwood area so as to raise their taxes about 25 per cent above those required to be paid on similar property in the adjacent Riviera and Pacific Palisades areas, and that the board of supervisors, sitting as a board of equalization, arbitrarily refused to correct these assessments.

At the trial of this action, which was before the court sitting without a jury, the only evidence received was the record of the proceedings before the board of equalization, including exhibits. The trial court concluded that there was substantial evidence in that record to sustain the decision of the board and gave judgment for defendants, from which plaintiffs have appealed.

The legal standard by which the action of the board may be reviewed judicially was stated in Bank of America v. Mundo, 37 Cal.2d 1, 5 [ 229 P.2d 345 ]: “The duty of determining the value of the property…