Two

This case concerns the County of Orange’s property tax reassessment of a retail shopping center located in the City of Westminster. The assessment appeals board and the trial court both concluded reassessment was proper because there was a change of ownership of the subject property when it was purchased by the long-term lessee and a third party investor. We conclude there was no change of ownership for property tax purposes and reverse the trial court’s judgment.

I

The parties do not dispute the facts of the various transactions in this case, only the legal conclusions to be drawn from them. The appeal concerns the Golden Westminster Specialty Center located at 15212 and 15300 Golden-west Street (the property). It consists of two adjoining parcels of improved real property identified as assessor’s parcel Nos. 142-383-13 and 142-401-62.

In 1977, the owners of the subject property entered into a 60-year ground lease with Golden Westminster Specialty Center (Golden Westminster). The term was from June 15, 1977, to June 14, 2037. The lease contained a purchase option permitting Golden Westminster to purchase the subject property during either the 25th year of the ground…