Holland v. Assessment Appeals Board No. 1, 167 Cal. Rptr. 3d 74

Proposition 13 caps property tax on real property by basing assessed value on acquisition (full cash value) and leaves "change in ownership" definitions mainly to the Legislature.
Revenue & Taxation Code § 62.1(a)(1) deems transfer of a mobilehome park to a resident-formed nonprofit or similar entity not a change in ownership (no reassessment at acquisition).
To prevent permanent avoidance of reassessment when resident corporations transfer membership interests, the Legislature enacted § 62.1(b): subsequent transfers of shares/memberships are "a change in ownership of a pro rata portion of the real property of the park," with the pro rata portion defined by a fractional formula.
Santa Barbara Assessor reassessed 26 sales where owners sold both their membership interest and mobilehome; the Assessor used the SBE-recommended "extraction method" (subtract mobilehome value from total purchase price, treat remainder as value of the underlying fractional park interest).
The Santa Barbara Assessment Appeals Board adopted a different appraisal formula (Fractional interest × FMV of entire park = FMV of fractional interest) and rejected the Assessor’s method; trial court denied the Assessor’s writ petition and the Court of Appeal affirmed.
California Supreme Court granted review to decide whether § 62.1(b) mandates a particular appraisal formula or merely defines the unit of property subject to reassessment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 62.1(b) prescribes a specific appraisal formula (fractional interest × FMV of entire park) for valuing the pro rata portion when a membership interest is transferred	Assessor: § 62.1(b) only defines the unit (a pro rata fractional interest) and does not mandate any particular appraisal method; SBE extraction method is permissible	Appeal Board / Respondents: § 62.1(b)’s multiplication language requires appraising the fractional interest as that fraction of the entire park’s FMV (uniform per-share valuation)	Held: § 62.1(b) defines the unit of real property deemed to change ownership but does not prescribe a specific appraisal formula; reversal of Court of Appeal and remand (extraction method not foreclosed)
Whether deference to the State Board of Equalization (SBE) supports the Assessor’s extraction method	Assessor: SBE guidance (LTA No. 99/87) advising the extraction method is entitled to deference; SBE has expertise and sponsored the statute	Respondents: SBE’s position is not longstanding or consistent and cannot displace the statutory text adopted by the Appeals Board	Held: Court gives respectful consideration to SBE guidance but rests decision on statutory construction; SBE’s interpretation supports but is not dispositive — § 62.1(b) remains silent on appraisal method and SBE’s extraction method is not barred

Pacific Southwest Realty Co. v. County of Los Angeles, 1 Cal.4th 155 (discusses Legislature’s role in defining change in ownership under Prop. 13)
Yamaha Corp. of America v. State Bd. of Equalization, 19 Cal.4th 1 (agency interpretations entitled to respect; degree of deference is situational)
Skidmore v. Swift & Co., 323 U.S. 134 (agency interpretations are entitled to respect proportionate to their persuasiveness)
Auerbach v. Assessment Appeals Bd. No. 1, 39 Cal.4th 153 (context on reassessment and change in ownership doctrines)
Horwich v. Superior Court, 21 Cal.4th 272 (statutory text controls where plain and unambiguous)