Helene Curtis, Inc. v. Los Angeles County Assessment Appeals Boards
Opinion
lead Opinion
Cooper, J.
This appeal is from a judgment denying a petition for a writ of mandate, to require the Los Angeles County Assessment Appeals Boards (board) 1 to (1) set aside the denial of petitioner Helene Curtis, Inc.’s (Curtis) 1997 application for reduction of property tax assessment, (2) hold a hearing on that application, and (3) enroll Curtis’s opinion of market value, because of the board’s failure to determine the application within two years after its filing (Rev. & Tax. Code, section 1604, subds. (c), (d)). 2 The trial court denied the petition, principally on grounds Curtis was estopped from claiming the benefits of subdivision (c). Although we agree with that *33 conclusion, we also conclude that Curtis is entitled to a board hearing on the merits of its application. We therefore reverse the judgment and direct the issuance of a limited writ of mandate, requiring the board to determine Curtis’s application on its merits.
FACTS
The backdrop of the contest in this case is subdivision (c), which relevantly provides: “If the county assessment appeals board fails to hear evidence and fails to make a final determination on the application for reduction in assessment of property…