Pueblos Del Rio South v. City of San Diego

Opinion

HUFFMAN, J.

On this appeal, we enter the fascinating world of real property reassessments after the passage of Proposition 131 to determine whether a corporate reorganization, exempt from state and federal income taxation, results in a “change of ownership” under the Revenue and Taxation Code thereby triggering reassessment of the real property transferred.

*896Revenue and Taxation Code section 642 was enacted as part of the legislative effort to interpret when a change of ownership has occurred under Proposition 13. (Sav-on Drugs, Inc. v. County of Orange (1987) 190 Cal.App.3d 1611, 1617…