SSL Landlord, LLC v. Cnty. of San Mateo

Plaintiffs SSL Landlord, LLC, SSL Tenant, LLC, and Health Care Reit, Inc. (hereinafter collectively referred to as "Silverado") appeal from a post judgment order denying a motion for attorney fees under Revenue and Taxation Code sections 1611.6 and 5152. 1 We affirm.

*386 FACTUAL AND PROCEDURAL BACKGROUND

The order denying Silverado's request for attorney fees relates to its tax refund lawsuit which is the subject of an appeal resolved in a separate opinion. (See SSL Landlord, LLC v. County of San Mateo , 2019 WL 1771959 (April 23, 2019, A150878) [nonpub. opn.].) We set forth only those facts that are necessary to resolve this appeal.

Silverado purchased an assisted living and memory care facility, known as the Silverado Senior Living Belmont Hills (property). The San Mateo County Assessor (Assessor) assessed the property's fair market value for property tax purposes at $ 26.4 million for the October 14, 2011 base year value assessment and the 2012/2013 regular assessment.

Silverado filed administrative appeals, seeking a refund of paid property taxes based on a challenge to the Assessor's valuation. Following a three-day hearing, the San Mateo County Assessment Appeals Board…