Main & Von Karman Associates v. County of Orange
Opinion
Opinion
Sills, J.
Plaintiff Main & Von Karman Associates (M&VK) appeals from a judgment denying its claim for refund of real property taxes. Because the county assessor failed to follow the mandatory provisions of rule 4 of the State Board of Equalization (Cal. Code Regs., tit. 18, §4) in using the comparable sales approach to value in calculating the fair market value of the properties, we reverse.
Facts
M&VK is the owner of two commercial properties in Irvine that lie adjacent to one another. The “Main Street parcel” consists of a commercial building and land located at 2300 Main Street. It was purchased on December 31, 1985, for $9,625,000. The “Von Karman parcel” consists of an office building and land located at 17900 Von Karman Avenue. It was purchased the same day for $8,222,290. At the time of the sales, Western Digital Corporation was leasing both properties at a net rate of 95 cents per square foot.
The county assessor assessed the parcels as of December 31, 1985, at an amount equal to their purchase price. As permitted by section 2 of article XIII A of the California Constitution (commonly known as Proposition 13), the assessor increased the assessments on each parcel by 2…