El Dorado Palm Springs, Ltd. v. Riverside County Board of Supervisors

*1265Opinion

GAUT, J.

1. Introduction

Revenue and Taxation Code section 51,1 enacted in 1978 as Proposition 8, allows the taxable value of real property to be reduced due to a decline in value.2

In 1997, plaintiff El Dorado Palm Springs, Ltd., a partnership (El Dorado), prevailed on an assessment appeal and obtained a reduction in a real property tax assessment for the tax year 1993.3 El Dorado failed to obtain a similar reduction for the five tax years 1994 through 1998. In 1999, El Dorado then filed suit seeking tax refunds for all five years. On appeal, El Dorado challenges the trial court’s…