Prang v. Assessment Appeals Bd. No. 6 CA2/1

── Prang v. Assessment Appeals Bd. No. 6 CA2/1 ── Court: California Court of Appeal Date: May 29, 2026 Category: General Filed 5/29/26 Prang v. Assessment Appeals Bd. No. 6 CA2/1 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION ONE JEFFREY PRANG, as Los B342735, B345399 Angeles County Assessor, (Los Angeles County Plaintiff and Appellant, Super. Ct. No. 23SMCP00421) v. ASSESSMENT APPEALS BOARD NO. 6 OF THE COUNTY OF LOS ANGELES, Defendant and Respondent; SEAN HOOSHANG NAMVAR, et al., Real Parties in Interest and Respondents. APPEALS from a judgment of the Superior Court of Los Angeles County, Mark A. Young, Judge. Affirmed in part, reversed in part, and remanded with directions.  Renne Public Law Group, Michael K. Slattery, Thomas G. Kelch, Ryan P. McGinley-Stempel, and Mauricio A. Grande for Plaintiff and Appellant. No appearance for Defendant and Respondent. Law Office of Bruce Altschuld and Bruce E. Altschuld for Real Parties in Interest and Respondents. _______________________________ Plaintiff and Appellant, Los Angeles County Assessor Jeffrey Prang (the Assessor), appeals from a judgment denying his petition for a writ of administrative mandamus under Code of Civil Procedure section 1094.5 or a writ of traditional mandamus under Code of Civil Procedure section 1085.1 The Assessor’s petition challenged a decision by Defendant and Respondent, Assessment Appeals Board No. 6 of the County of Los Angeles (the Board). The Board’s decision concerned the assessed value of the property at 416 N. Rockingham Avenue in Los Angeles (the Property), owned by Real Parties in Interest and Respondents Hooshang Sean Namvar and Shiva Nataly Haronnian (the Owners). We conclude that the trial court erred by sustaining the Owners’ demurrer to the Assessor’s administrative mandate claim on statute of limitations grounds. We further conclude that the trial court properly denied the Assessor’s traditional mandate claim on the merits at trial. Accordingly, we affirm the judgment as to the traditional mandate claim, reverse the judgment as to the administrative mandate claim, and remand for a trial on the merits of the latter claim. 1 Undesignated statutory references are to the Code of Civil Procedure. 2  BACKGROUND A. Property taxes and assessment appeals boards “In 1978, Proposition 13 amended the California Constitution to limit real property taxes to 1 percent of a property’s base year value adjusted annually by an inflation factor not to exceed 2 percent of the prior year’s value. [Citations.] Proposition 13 set the base year value used to determine each year’s taxes at the value the local assessor set on the 1975-1976 tax bill.” (William Jefferson & Co., Inc. v. Orange County Assessment Appeals Bd. No. 2 (2014) 228 Cal.App.4th 1, 9 (William Jefferson).) “Since the passage of Proposition 13, an assessor may reassess real property only if one of three triggering events has occurred—namely, (1) when the property has been ‘purchased,’ (2) when the property is ‘newly constructed,’ or (3) when ‘a change in ownership has occurred.’ ” (Prang v. Los Angeles County Assessment Appeals Bd. No. 2 (2020) 54 Cal.App.5th 1, 12 (Prang).) Upon reassessment, the base year value is the fair market value on the date of the purchase or change in ownership. (Rev. & Tax. Code, § 110.1, subds. (a)-(b).)