Board

This appeal is from a judgment denying a petition for a writ of mandate, to require the Los Angeles County Assessment Appeals Boards (board) [1] to (1) set aside the denial of petitioner Helene Curtis, Inc.'s (Curtis's) 1997 application for reduction of property tax assessment, (2) hold a hearing on that application, and (3) enroll Curtis's opinion of market value, because of the board's failure to determine the application within two years after its filing (Rev. & Tax. Code, section 1604, subdivisions (c), (d)). [2] The trial court denied the petition, principally on grounds Curtis was estopped from claiming the benefits of subdivision (c). Although we agree with that conclusion, we also conclude that Curtis is entitled to a board hearing on the merits of its application. We therefore reverse the judgment and direct the issuance of a limited writ of mandate, requiring the board to determine Curtis's application on its merits.

The backdrop of the contest in this case is subdivision (c), which relevantly provides: "If the county assessment appeals board fails to hear evidence and fails to make a final determination on the application for reduction in assessment of…