926 North Ardmore v. County of L.A.

Summary

The California Supreme Court held that a county may impose a documentary transfer tax on written instruments transferring interests in a legal entity that owns real property when the transaction effects a sale, meaning an actual transfer of beneficial ownership for consideration. The court concluded that the transfer of partnership interests caused a statutory change in ownership of the apartment building, and that the written transfer agreements were taxable even though they did not identify the building and were not recorded. The court affirmed rejection of the taxpayer's refund claim.