Flightsafety International Inc. v. Los Angeles County Assessment Appeals Board

Summary

Under Revenue and Taxation Code section 1604, a county assessment appeals board must hear and decide a taxpayer’s application for reduction of an assessment within two years of the application. If the appeals board fails to act within two years, the taxpayer’s opinion of value becomes the assessed value, both for the year listed in the application and for subsequent years until the board makes a final determination on the application. In this case, under the mandate of section 1604, the appeals board entered the taxpayer’s opinion of value—which was zero—on the assessment roll for 1992, but did not do so for the years 1993 through 1998, the year in which the board made its final determination on the taxpayer’s 1992 application. The taxpayer sought, and obtained, a peremptory writ of mandate requiring the appeals board to enroll the taxpayer’s opinion of value for tax years 1993 through 1998. The appeals board appealed, claiming the taxpayer failed to exhaust its administrative remedies and was not otherwise entitled to a writ. Finding no error, we affirm the trial court’s judgment granting the writ.

Factual and Procedural Background

The Los Angeles County…