Harmony Gold U.S.A., Inc. v. Cnty. of L. A.

*824This appeal requires us to consider two Revenue and Taxation Code1 sections that address a real property's "base-year value" (base value), a core metric for assessing property taxes in California. Specifically, we must consider the interplay between section 51.5, subdivision (a), which removes any otherwise applicable time limits on the assessor's ability to correct base value errors that do not involve an exercise of judgment (so-called "nonjudgmental error"), and section 80, subdivision (a)(5), which limits the years for which a property owner is entitled to have a property's base value…