Wm. Jefferson & Co. v. Assessment Appeals Bd.
Opinion
Opinion
FACTS AND PROCEDURAL HISTORY2
The property at issue is a single-family home located in Irvine, California. William A. Kent purchased the property for $305,000 in 1990. After several other transfers for which there are no details in the record, Michael Kim sold the property to Gopal Productions, Inc. (Gopal) for $271,000 in December 1992. Gopal recorded the deed transferring the property, but failed to file a change of ownership statement, which would have alerted the Assessor to determine whether the transfer constituted a change of ownership requiring a new base year value for the property. Gopal filed the change of ownership statement in June 1993 after receiving notice a penalty would be imposed if it did not promptly file the statement. That same month Gopal also recorded a quitclaim deed transferring the property to Jefferson. All parties agree the transfer to Jefferson was not a change of ownership affecting the property’s base year value because Gopal and Jefferson were related corporations. In October 1993, the Assessor sent Gopal a supplemental assessment notice, which acknowledged the December 1992 change of ownership from Kim to