County of Los Angeles v. Raytheon Co.

The County of Los Angeles (County) appeals from the judgment entered in this property tax refund action, contending the trial court erred in ruling Raytheon Company and the DirecTV Group, Inc., successors in interest to Hughes Aircraft Company (Hughes), have standing to seek a refund of property tax levied in the tax year 1991-1992 on parcels occupied by Hughes under long-term leases that require Hughes to pay the real property taxes. The County also contends the refund action is time-barred notwithstanding the parties’ written stipulation to waive any limitations defense to this refund action. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

1. Hughes’s Long-term Leases

In December 1983 Hughes entered into a 55-year triple net lease (consisting of an initial term of 25 years plus six additional five-year options) to occupy two office buildings on land identified as Los Angeles County Assessor’s parcel Nos. 4138-004-014 (014) and 7310-016-066 (066) and reported to the county assessor as locations 01-11 and 01-14 for personal property tax purposes. In accordance with the express terms of the lease, Hughes (or Raytheon, Hughes’s successor, which took over the lease in 1997)…