Harmony Gold U.S.A., Inc. v. Cnty. of L. A.

*824 This appeal requires us to consider two Revenue and Taxation Code 1 sections that address a real property's "base-year value" (base value), a core metric for assessing property taxes in California. Specifically, we must consider the interplay between section 51.5, subdivision (a), which removes any otherwise applicable time limits on the assessor's ability to correct base value errors that do not involve an exercise of judgment (so-called "nonjudgmental error"), and section 80, subdivision (a)(5), which limits the years for which a property owner is entitled to have a property's base value reassessed.

Appellant Harmony Gold, Inc. (Harmony) overpaid in property taxes as a result of the assessor's nonjudgmental error; specifically, an erroneous change-in-ownership determination that reset its property's base value. Los Angeles County (the County) refunded the taxes Harmony overpaid beginning in the year Harmony first challenged the erroneous base value, but not for prior years. In the action underlying Harmony's appeal, Harmony sought to recover tax overpayments for those prior years. It also sought a declaration and writ requiring the auditor-controller to correct the tax…