Geneva Towers Ltd. Partnership v. City & County of San Francisco

Opinion

MORENO, J.

In this case, we consider what statute of limitations applies when a county or city fails to act upon a claim for refund of property taxes within six months and the taxpayer elects under Revenue and Taxation Code section 5141, subdivision (b) to “consider the claim rejected and bring an action” in superior court. For the reasons that follow, we conclude that the applicable statute of limitations is the six-month period set forth in Revenue and Taxation Code section 5141, subdivision (a), rather than the general four-year statute of limitations set forth in Code of Civil…