Prang v. Los Angeles County Assessment Appeals Bd.

Summary

The court held that a transfer of real property from a corporation to a trust does not qualify for the proportional-transfer exclusion when the corporation's nonvoting shareholders lose their beneficial interests. Under the governing statute, proportional ownership interests in corporate real property are measured by all stock carrying beneficial economic interests, not merely voting stock. The court also concluded that the agency's regulation and interpretive materials did not warrant a contrary interpretation, and it affirmed the Court of Appeal.