Prudential Insurance of America v. City & County of San Francisco

Opinion

WHITE, P. J.

This case involves a dispute between respondent Prudential Insurance Company of America (Prudential) and appellant City and County of San Francisco, as represented by its assessor’s office (the Assessor), over the amount of real property taxes owed on a hotel purchased by Prudential. The central issue is whether a debt at a below-market interest rate which a buyer assumes from a seller must be discounted to its cash equivalent value in determining for purposes of property tax the value of the property sold. We hold that such discounting is required by state law. We also…