City of Los Angeles v. County of Los Angeles

We granted a rehearing in the above entitled case in order to give further consideration to the city’s argument that it qualified under section 214.8 of the Revenue and Taxation Code. We conclude that *970 it does not, and, therefore, re-adopt our opinion as originally filed with some additions.

This is an action brought by the City of Los Angeles to recover local property taxes paid to the County of Los Angeles, The taxes were levied by the county, certain special districts, and a school district on property consisting of a youth camp (Decker Canyon Youth Camp) owned by the city outside of its territorial boundaries. Both the city and county agree that the property is not entitled to the government exemption contained in article XIII, section 1 of the California Constitution. 1 The city contends that it is eligible for the welfare exemption found in article XIII, section 1c of the California Constitution and in Revenue and Taxation Code section 214. The county submits that the tax was correctly levied and collected, in that the city does not qualify for the welfare exemption. The city duly filed its claim for welfare exemption which claim was denied. A timely claim for…