Joseph E. Holland, as Assessor v. Assessment Appeals Board No. 1, Defendant And…

Summary

The court held that Revenue and Taxation Code section 62.1, subdivision (b), identifies the fractional portion of a resident-owned mobilehome park whose transfer triggers reassessment but does not prescribe the method for appraising that portion. Because the Assessment Appeals Board incorrectly construed the statute as mandating a fractional-interest-times-entire-park-value formula, its decisions were erroneous and the Assessor's writ petition should have been granted. Justice Werdegar concurred in the judgment but expressed doubt that the extraction method properly values the undivided fractional interest required by the statute.