Mission Housing Development Co. v. City & County of San Francisco
Opinion
Opinion
Jones, J.
This is an action for refund of property taxes brought by appellants (hereafter Taxpayers), a number of corporations and limited partnerships that own low-income housing projects in the City of San Francisco, against respondent the City and County of San Francisco (hereafter the City). In this appeal, Taxpayers challenge the trial court’s judgment upholding the San Francisco Assessment Appeals Board’s (hereafter AAB) decision denying a number of applications for reduction in assessment filed by Taxpayers for tax years 1982-1983 through 1987-1988.
Summary of Issues and Conclusions
Due to the number of issues the parties have raised on appeal, we begin our opinion by summarizing the major issues and our conclusions thereon.
(1) Taxpayers contend they are entitled to have their opinions of the value of their properties, stated in their applications for reduction in assessment, inserted on the county assessment roll for tax years 1983-1984 through 1986-1987 because the AAB failed to hear and make a final determination on their applications within two years after they were filed, as required by Revenue and Taxation Code section 1604, subdivision (c). The City contends…