Fashion Valley Mall, LLC v. County of San Diego

Opinion

IRION, J.

Fashion Valley Mall, LLC (Mallco), appeals from the trial court’s summary judgment ruling in favor of the County of San Diego (the County) on Mallco’s complaint for a refund of property taxes. At issue is the trial court’s ruling that a 100 percent change in ownership occurred when record title in the Fashion Valley Shopping Mall in San Diego (the Mall) was transferred by Equitable Life Assurance Company of the United States (Equitable) to Mallco as Equitable’s initial capital contribution to Mallco’s parent company, Fashion Valley MM, LLC (FVM), which gave Equitable a 50…