Scott v. Marin County Assessment Appeals Bd. CA1/4

CourtCalifornia Court of Appeal
DecidedMarch 26, 2026
DocketA171613
StatusUnpublished

This text of Scott v. Marin County Assessment Appeals Bd. CA1/4 (Scott v. Marin County Assessment Appeals Bd. CA1/4) 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
Scott v. Marin County Assessment Appeals Bd. CA1/4, (Cal. Ct. App. 2026).

Opinion

Filed 3/26/26 Scott v. Marin County Assessment Appeals Bd. CA1/4

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

SHELLY SCOTT, as Marin County Assessor, etc., A171613 Plaintiff and Respondent, (Marin County v. Super. Ct. No. CV0000809) MARIN COUNTY ASSESSMENT APPEALS BOARD, Defendant and Respondent;

MICHAEL DAY et al., Real Parties in Interest and Appellants.

In this administrative mandate proceeding, Michael Day and Laura Allen (Real Parties) appeal from the trial court’s issuance of a writ to the Marin County Assessment Appeals Board (Board) ordering vacatur of the Board’s ruling in their favor. The central issue is whether, for assessment purposes under Revenue and Taxation Code section 69.5, the Real Parties are entitled to transfer to their present residence (Property) the base-year value of a residence Day previously owned. The trial court granted writ relief to the Marin County Assessor (Assessor), but remanded for further administrative proceedings.

1 What complicates the Revenue and Taxation Code section 69.5 issue here is that the Real Parties entered into an agreement October 29, 2018 with Allen’s mother, Kathleen Burry, two days before the Property’s purchase on October 31, 2018, and under a co-ownership agreement (the Co-Ownership Agreement or the Agreement), Burry, as trustee for the Kathleen Burry Revocable Trust, is the record title holder and borrower for the Property. The Board decided that, regardless of Burry’s status as record title holder, the Real Parties hold a beneficial ownership in the Property, and as a result, they are the owners of the Property and are entitled to a base-value transfer. The Board found by clear and convincing evidence “that the legal title holder, Ms. Burry, intended to and did transfer all beneficial ownership of the Property to [the Real Parties].” In support of her writ petition, the Assessor argued and the trial court agreed that the Board’s decision was erroneous because Burry could not effect a transfer of the beneficial interest in the Property via the Co-Ownership Agreement two days before her purchase of the Property, since California law requires that she hold a present interest in real property in order to transfer it. But despite having so ruled, the trial court did not rule outright for the Assessor. It remanded for consideration of an issue the court viewed as unaddressed by the Board—the Real Parties’ argument that they obtained beneficial ownership of the Property not via a transfer from Burry, but because Burry acted solely as their agent in arranging the Property’s purchase. Here on review, the Real Parties contend there was no need for a remand to the Board. In their view, they should win outright because the Board did address the agency issue, it correctly decided the issue in their favor, and we should now endorse that ruling. Rather than address this

2 argument, defend the trial court’s decision on the merits, and grapple directly with the agency issue, the Assessor’s brief in response argues only that the Real Parties have appealed from an interlocutory, nonappealable order. We reject that procedural argument. Because the trial court granted the writ without retaining jurisdiction or reserving any issues for the court’s further consideration, we conclude the Real Parties seek review of a final, appealable order. On the merits, however, we reverse because the premise of the trial court’s ruling is legally incorrect. As noted, the court granted writ relief on the ground that a base-year transfer requires the transfer of a present interest, and Burry could not transfer beneficial ownership of the Property to the Real Parties before purchasing it because she had nothing to transfer when the Co-Ownership Agreement was signed. But in so ruling, the court focused on the wrong date. The issue here is not whether, as of October 29, 2018, when the Co-Ownership Agreement was signed, Burry transferred anything to the Real Parties; instead what matters is whether, under the Co- Ownership Agreement, as of October 31, 2018 Burry was obligated to, and did, transfer to the Real Parties beneficial ownership of the Property (with record title to be transferred later as soon as the Real Parties completed their divorce proceedings and obtained their own financing). Given this error, we must reverse because the trial court remanded to the Board for further proceedings “consistent with” its unqualified order granting the writ, which, naturally, may lead the Board to feel compelled to accept the erroneous premise on which the remand order is based, potentially foreclosing further review of the order Real Parties now place before us for review in the event the Assessor prevails in further proceedings before the Board. The trial court did, however, correctly see the need for the Board to

3 more fully address the agency issue, particularly since the Real Parties have staked their position on that issue all along. The Real Parties insist that there is no need for an administrative remand because, according to them, the Board has already decided the agency issue in their favor. We conclude that, if the Board’s decision addresses the agency issue, it does so incompletely on the present record. It is unclear, for example, whether a series of apparently inaccurate representations by Burry to Wells Fargo (the Property’s mortgage lender)— representations that seem to have been known to the Real Parties—may render the Co-Ownership Agreement unenforceable on public policy grounds. By raising this aspect of the agency issue, we do not intend to suggest in any respect how we might rule on it. We simply flag the matter of enforceability so that, at the conclusion of the proceedings before the Board, and in any further writ proceedings before the trial court, or eventually before this court, the record will be adequate for review. I. BACKGROUND In June 2020, Day applied to the Assessor for the application of the base-year value of a residence he previously owned to the Property for assessment purposes. The Assessor denied his application because, the Assessor concluded, “you are not the owner of the [Property], nor is the [P]roperty eligible for the homeowners’ exemption. (See Rev. & Tax Code § 69.5(b)(4).)” A. The Board Proceedings 1. Day’s Contentions Before the Board Day appealed the Assessor’s denial of his request for application of the value transfer to the Board. The Assessor conceded at the Board hearing that as long as one owner of the Property qualified for the transfer, the transfer was potentially applicable. In a letter brief to the Board, Day,

4 through his attorney, argued that the Property was eligible for the base-year value transfer and addressed the issue upon which the Assessor based her denial: whether the Real Parties were the true owners of the Property. Day asserted that he and Allen, soon to be married, had sought to replace Day’s previous residence with a new one and needed financing to do so. But Day “was in the process of finalizing a divorce, and under the divorce proceeding [Day] was not allowed to incur new debt without his soon to be ex- wife signing paperwork to authorize the new debt. [Day’s] ex[-wife] was unwilling to sign off on [Day] obtaining a new loan.” Unable to obtain financing, Day further asserted, the Real Parties asked Burry, Allen’s mother, to effect purchase of the Property on the Real Parties’ behalf as their agent and temporarily hold record title.

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Cite This Page — Counsel Stack

Bluebook (online)
Scott v. Marin County Assessment Appeals Bd. CA1/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-v-marin-county-assessment-appeals-bd-ca14-calctapp-2026.