Helene Curtis, Inc. v. Assessment Appeals Board

This case presents two issues: (1) Title 18, section 305, subdivision (e) of the California Code of Regulations (Rule 305(e)) prohibits amendment of applications for property tax refunds “to request relief additional to or different in nature from that originally requested” after the filing deadline. Is that regulation authorized by the State Board of Equalization’s (SBE) governing statutes? (2) Did applications for tax reductions which only stated challenges to escape assessments of personal property and fixtures include challenges to the underlying real property at the business location?

Helene Curtis, Inc. (Curtis), appeals from the denial of its petition for administrative mandamus. The trial court denied Curtis’s petition to compel the Assessment Appeals Board of Los Angeles County (AAB) either to grant a hearing on the valuation of all property located at its business location or to allow Curtis to amend its assessment reduction applications to include all property located at its business location. The AAB denied Curtis’s request to amend its application on the ground that the amendment was not permitted under Rule 305(e). Curtis contends that (1) “Rule 305(e) is a…