926 N. Ardmore Ave., LLC v. Cnty. of L. A.

*324 Here we consider whether the County of Los Angeles can impose a documentary transfer tax on a written instrument that transfers beneficial ownership of real property from one person to two others. We hold that the tax may be imposed if the document reflects a sale: that is, an actual transfer of legal beneficial ownership made for consideration.

I. FACTS AND PROCEDURE

A. Transactions Involving the Building

This case arises from a series of transactions among trusts maintained for the benefit of Averbook family members. Beryl and Gloria Averbook owned *325 an apartment building at 926 North Ardmore…