Sav-On Drugs, Inc. v. County of Orange

Opinion

CROSBY, J.

Under article XIIIA of the California Constitution, increases in appraised values of taxable real property are severely restricted; but a change in ownership will permit reassessment. In this case we are called upon to decide whether a corporate merger constituted a “change of ownership,” as that phrase is defined in the Revenue and Taxation Code and, if so, whether the Legislature’s interpretation of article XIII A, as expressed in that code, is constitutional.

I

Two corporations owning real property brought suit against the County of Orange and 15 municipalities for refunds…