Dear

Revenue and Taxation Code section 51.5 (all further unspecified statutory references are to this code) requires a county tax assessor to correct errors in the tax roll which are not based on judgment as to value in the same assessment year they are “discovered.” This case calls on us to plumb the murky waters of available remedies when the county assessor refuses the taxpayer’s request to correct such an error eight years after it was allegedly made and the normal time for appeal has expired.

In 1986 the Placer County Assessor (Assessor) determined there had been a change in ownership on property owned by plaintiffs to trigger a new “base year” for purposes of property valuation under article XIII A of the California Constitution. The determination triggered a supplemental assessment and was reflected in valuations for succeeding years.

In 1994 plaintiffs discovered facts which they claimed showed the Assessor had erred in determining that ownership had changed. After failing to persuade the Assessor, plaintiffs filed an appeal with the Placer County Assessment Appeals Board (AAB) to change the assessment. The AAB ruled it had no jurisdiction because the application was…