Bent

FACTS

In his petition for writ relief and complaint for declaratory relief, Bent alleged: Bent and Evans Sechrest (Sechrest) were each 50 percent partners in a general partnership that, inter alia, owned two properties in Venice, one in Vernon and one in North Hollywood. Sechrest died on February 12, 2008, and devised his partnership interest to Bent. Eventually, pursuant to a probate court order, Bent received a transfer of 100 percent of the partnership’s properties. Noguez issued notices that the properties in Vernon and North Hollywood were being reassessed on the grounds that there had been a change in ownership in 2008. Subsequently, Bent filed appeals with the Board and claimed that the properties should not have been reassessed because, under Revenue and Taxation Code section 64, subdivision (c)(2),2 there is no change in ownership of real property held by a partnership when one partner acquires all of the remaining ownership interests in that partnership. The Board, however, concluded that Bent’s tax appeals were untimely and denied them on that basis. Bent alleged that the Board erred because the tax appeals were timely filed within the one-year statute of limitations,…