Blue Hen Enterprises v. County of Imperial CA4/1

CourtCalifornia Court of Appeal
DecidedJune 19, 2013
DocketD059898
StatusUnpublished

This text of Blue Hen Enterprises v. County of Imperial CA4/1 (Blue Hen Enterprises v. County of Imperial CA4/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blue Hen Enterprises v. County of Imperial CA4/1, (Cal. Ct. App. 2013).

Opinion

Filed 6/19/13 Blue Hen Enterprises v. County of Imperial CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

BLUE HEN ENTERPRISES, LLC, D059898

Plaintiff and Appellant,

v. (Super. Ct. No. ECU05756)

COUNTY OF IMPERIAL et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Imperial County, Jeffrey B.

Jones, Judge. Affirmed.

Krakowsky Law Firm, Shinaan S. Krakowsky for Plaintiff and Appellant.

Schwartz Hyde & Sullivan, Laurel Lee Hyde; Schwartz Heidel Sullivan, Laurel

Lee Hyde, for Defendants and respondents.

Appellant Blue Hen Enterprises, LLC (Blue Hen) purchased real estate

encumbered with past-due property taxes. Blue Hen submitted requests to the Imperial

County Tax Assessor (Assessor) and the Imperial County Board of Supervisors (Board)

seeking a reduction in the past-due taxes based on its claim that the value of the property had been overassessed.1 The Assessor denied the request on untimeliness grounds, and

Blue Hen's appeal to the Board was denied by operation of law without a consideration of

the merits. Blue Hen then filed an action in superior court requesting an order

compelling the Assessor and the Board (respondents) to consider its request on the

merits. The trial court sustained respondents' demurrer and dismissed the action. Blue

Hen challenges this ruling on appeal.

We conclude that even assuming Blue Hen filed a timely claim for tax relief with

respondents, the trial court's order was correct because under the relevant statutory

scheme Blue Hen is precluded from obtaining its requested retroactive property tax relief.

FACTUAL AND PROCEDURAL BACKGROUND

The relevant facts are essentially undisputed. In April 2009, Blue Hen purchased

real property encumbered by outstanding taxes for the tax years 2006-2007 and 2007-

2008. The previous property owner had purchased the land in July 2006 for $31,780,000,

which included a $19,780,000 promissory note secured by a deed of trust on the property.

At the time of the 2006 purchase, the Assessor established the tax value of the property

(known as the "base year value") based on the purchase price. The 2006 base year value

was then used to calculate the taxes owed for the 2006-2007 and 2007-2008 tax years.

The previous owner failed to fully pay the taxes for the 2006-2007 and 2007-2008 tax

years, and also stopped making payments on the promissory note secured by the deed of

1 When reviewing property tax matters, a county board of supervisors sits as the county board of equalization. (Cal. Const., art. XIII, § 16; Rev. & Tax. Code, § 1601, subd. (a).) 2 trust. In December 2007 the deed of trust holder filed a notice of default, and in July

2008 acquired the property through foreclosure. In April 2009 Blue Hen purchased the

property from the deed of trust holder for $1,899,999.2

After Blue Hen purchased the property in 2009, it sent a letter to the Assessor

requesting to settle the past-due tax encumbrance on the property. In the May 28, 2009

letter, Blue Hen set forth a variety of reasons to support its claim that the assessed value

of the property at the time the past taxes accrued was too high. Blue Hen proposed a

lower valuation for the property so as to retroactively reduce the amount of taxes it owed

for the 2006 through 2008 tax years. Blue Hen did not seek prospective tax relief based

on the 2006 valuation because when Blue Hen purchased the property in 2009, the 2006

base year value was no longer operative since the property had been reassessed and the

base year value changed in 2008 and 2009 due to the foreclosure and subsequent

purchase by Blue Hen. (See fn. 4, post.)

By letter dated July 2, 2009, the Assessor responded that there were only two

options for reviewing established roll values and, if warranted, decreasing a property's

assessed value. The Assessor explained that the taxpayer must file an application for a

change of assessment with the local appeals board during the regular assessment filing

period for the tax year in question, or submit a request for informal review of the

valuation before the end of that tax year. The Assessor stated that because neither of

2 The 2006 purchase price was about $70,000 per acre, whereas the 2009 purchase price was about $5,000 per acre. 3 these options was exercised by Blue Hen or prior owners, the Assessor had no legal

means to review the request. Accordingly, the Assessor denied the claim as untimely.

After receiving the Assessor's response, Blue Hen sent a form entitled "CLAIM

FOR DAMAGES AGAINST THE COUNTY OF IMPERIAL" dated October 14, 2009,

to the Board. In the claim, Blue Hen reiterated the request it had made to the Assessor

for a reduction in the valuation of the property and the past-due taxes. Blue Hen

emphasized in its claim that the valuation of the property giving rise to the back taxes

was not properly determined, and it intended to rely on "all available legal remedies,

statutory or otherwise, for appropriate relief."

By letter dated December 3, 2009, the Board rejected Blue Hen's claim "by

operation of law."

In July 2010 Blue Hen filed a complaint in superior court requesting that the court

remand the matter to the Board to review Blue Hen's tax assessment claims on the merits.

The trial court sustained respondents' demurrer with leave to amend, ruling that Blue

Hen's request for a reduction in the value was untimely under Revenue and Taxation

Code sections 1603 and 1605 (which essentially require that the request be filed during

the year the valuation was made).3

In November 2010, Blue Hen filed an amended pleading requesting that the court

issue an order remanding the matter to the Assessor or the Board to consider Blue Hen's

request for relief on its merits under a statutory provision (§ 51.5) which contains a four-

3 Subsequent unspecified statutory references are to the Revenue and Taxation Code. 4 year limitations period for reductions in base year value involving an assessor's error in

judgment. Respondents again filed a demurrer, arguing that Blue Hen was improperly

seeking to avoid the relevant limitations period by characterizing its request for relief as a

timely section 51.5 challenge to the 2006 base year value. Alternatively, respondents

argued that even if Blue Hen had properly requested section 51.5 relief, the statutory

scheme (including § 80, subd. (a)(5)) permitted only prospective relief from the date of

application for relief and forward, and hence Blue Hen was precluded from obtaining

retroactive relief for the 2006 through 2008 tax years based on its 2009 application for

relief.

In opposition to the demurrer, Blue Hen argued that its communications to

respondents sufficed to state a claim for a reduction in the 2006 base year value under

section 51.5; its claim for retroactive tax relief was timely under section 51.5's four-year

limitations period; and a section 51.5 claim was not subject to the prospective-only relief

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Osco Drug, Inc. v. County of Orange
221 Cal. App. 3d 189 (California Court of Appeal, 1990)
SYNGENTA CORP PROTECTION, INC. v. Helliker
42 Cal. Rptr. 3d 191 (California Court of Appeal, 2006)
Kuperman v. San Diego County Assessment Appeals Bd. No. 1
40 Cal. Rptr. 3d 703 (California Court of Appeal, 2006)
Metropolitan Culinary Services, Inc. v. County of Los Angeles
61 Cal. App. 4th 935 (California Court of Appeal, 1998)
Montgomery Ward & Co. v. County of Santa Clara
47 Cal. App. 4th 1122 (California Court of Appeal, 1996)
Sunrise Retirement Villa v. Dear
58 Cal. App. 4th 948 (California Court of Appeal, 1997)
Sea World, Inc. v. County of San Diego
27 Cal. App. 4th 1390 (California Court of Appeal, 1994)
Ass'n of Graduate Student Employees v. Public Employment Relations Board
6 Cal. App. 4th 1133 (California Court of Appeal, 1992)
Little v. LOS ANGELES COUNTY ASSESSMENT APPEALS BOARDS
66 Cal. Rptr. 3d 401 (California Court of Appeal, 2007)
Sanchez v. Swissport, Inc.
213 Cal. App. 4th 1331 (California Court of Appeal, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Blue Hen Enterprises v. County of Imperial CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blue-hen-enterprises-v-county-of-imperial-ca41-calctapp-2013.