William Jefferson & Co. v. Orange County Assessment Appeals Board No. 2

Nearly 15 years after the Orange County Assessor (Assessor) established the base year value used to assess real property taxes against plaintiff William Jefferson & Co., Inc.’s (Jefferson) property, Jefferson appealed to defendant Orange County Assessment Appeals Board No. 2 (Appeals Board) claiming the Assessor made a clerical error in valuing theproperty. The Appeals Board conducted an evidentiary hearing and denied the appeal on the ground Jefferson had waited too long to challenge the Assessor’s base year value determination. The Appeals Board found Jefferson based its appeal not on a clerical error but on the Assessor’s error in establishing the property’s value, and therefore Jefferson failed to comply with Revenue and Taxation Code sections 51.5, subdivision (b), and 80, subdivision (a)(3), which required Jefferson to appeal within four years of the Assessor’s base year value determination.

Jefferson filed this action below seeking to compel the Appeals Board to grant Jefferson’s appeal and direct the Assessor to change the property’s base year value from $305,000 to $271,000. Jefferson, however, failed to address the Appeals Board’s determination that it lacked…