926 North Ardmore Avenue, LLC, Plaintiff and Appellant v. County of Los Angeles, Defendant and Respondent.

Summary

The court held that California's documentary transfer tax may apply to a written instrument transferring interests in an entity that owns real property when the transaction constitutes a sale of beneficial ownership for consideration and results in a statutory change in ownership. Because the instruments transferred beneficial interests in the building to new owners for promissory-note consideration, the county properly imposed the tax even though the instruments did not mention the building and were not recorded. The judgment affirming denial of the refund was affirmed.