Steinhart

Article XIII A of the California Constitution (article XIII A), which the voters adopted in June 1978 as Proposition 13, limits the ad valorem tax on real property to 1 percent of the property’s “full cash value.” (Art. XIII A, § 1, subd. (a).) As relevant here, section 2, subdivision (a), of article XIII A (sometimes hereafter section 2, subdivision (a)), defines “full cash value” as the 1975-1976 assessed value of the property adjusted for inflation, or the appraised value of the property upon a “change in ownership” occurring after the 1975-1976 assessment. The issue this case presents is whether a “change in ownership” occurred within the meaning of this section upon the death of a trust settlor who transferred her residence to a trust that was revocable during her life, who was the sole present beneficiary of that revocable trust, and who provided in the trust document that upon her death the trust would become irrevocable and her sister would have the right to occupy the residence during her lifetime. Preliminarily, we must determine whether the settlor’s surviving sister properly filed this action to challenge an administrative determination that a change in…