Holland v. Assessment Appeals Bd.

Summary

The court held that Revenue and Taxation Code section 62.1, subdivision (b) identifies the fractional real-property interest subject to reassessment when an interest in a resident-owned mobilehome park is transferred, but does not prescribe a particular appraisal formula. Because the Assessment Appeals Board incorrectly required a formula based on the fractional interest multiplied by the fair market value of the entire park, its decisions rested on an erroneous statutory construction. The court reversed the Court of Appeal and remanded for further proceedings, without deciding which appraisal method should ultimately be used.