Zapara

— Thomas Zapara appeals a judgment against him in favor of the County of Orange in his action for refund of property taxes. The sole issue raised on appeal is whether the transfer of title to real property by a partnership to a general partner, who by virtue of having purchased all minority partnership interests has become the sole partner and sole owner of the partnership and its property, constitutes a “change of ownership” under Revenue and Taxation Code section 60 permitting a reassessment of the property for property tax purposes. We affirm.

Zapara, Thomas Gray and Richard Kalferd formed a general partnership in 1969 and held interests in the partnership of approximately 68 percent, 17 percent and 15 percent respectively. The partnership’s sole asset was a parcel of real property located in Irvine.

In June 1986 Zapara used his own funds to purchase Gray’s and Kalferd’s minority interests. An amended statement of partnership was recorded on July 14 acknowledging the transfer, stating the partnership was not dissolved but continued with Zapara as its sole partner, and stating Zapara had the sole authority to convey title to the partnership’s real property.

On…