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Hovannisian v. City of Fresno
A complaint regarding a special assessment cannot be resolved through preemptive suit; it must instead be paid and then resolved through an action for a refund. 		Tax 5DCA Dec. 26, 2024
Grand Canyon University v. Cardona
University's non-profit status was subject to the requirements of the Higher Education Act, not the Internal Revenue Code's 501(c)(3) requirements. 		Administrative Agencies, Tax 9th Nov. 11, 2024
Amended Opinion: U.S. v. Page
Statute of limitations for action to recover erroneous tax refund did not begin to run until the check clearance date because that was when the refund was made, not when the taxpayer received the check. 		Tax 9th Sep. 13, 2024
Brown v. Commissioner of Internal Revenue
IRS Collection Division's return of taxpayer's offer-in-compromise as nonprocessable within the 24-month timeframe for considering such offers constituted a timely rejection of the offer. 		Tax 9th Aug. 30, 2024
Libitzky v. U.S.
Taxpayers were not entitled to recover $692,690 in overpaid taxes where the claim was made outside of the lookback period. 		Tax 9th Aug. 6, 2024
Loeber v. Lakeside Joint School District
California Constitution's Article XIII C, Section 3's initiative power does not apply to initiatives seeking to create tax exemptions, rather than reducing or repealing a tax. 		Tax 6DCA Jul. 11, 2024
U.S. v. Page
Statute of limitations for action to recover erroneous tax refund did not begin to run until the check clearance date because that was when the refund was made, not when the taxpayer received the check. 		Tax 9th Jun. 27, 2024
Moore v. United States
The Mandatory Repatriation Tax is an indirect tax on income that does not require apportionment. 		Tax USSC Jun. 21, 2024
Connelly v. U.S.
A corporation's contractual obligation to redeem shares did not reduce a corporation's value for the purposes of the federal estate tax. 		Tax USSC Jun. 7, 2024
Prang v. Los Angeles County Assessment Appeals Board
"Change in ownership" measures proportional beneficial ownership interests in corporate real property by corporate stock generally with no special analysis as to whether the stock is voting or non-voting. 		Tax CASC May 31, 2024
Equinix LLC et al. v. County of Los Angeles
Despite being the property's original owner, because property lessor's lease term was less than 35 years, it triggered change in ownership and subsequent property tax reassessment. 		Real Property, Tax 2DCA/1 May 13, 2024
Bekkerman v. California Dept. of Tax and Fee Admin.
Regulations allowing cellphones to be taxed based on their unbundled price rather than the cost with bundled service did not violate Revenue and Tax Code provisions. 		Tax 3DCA Feb. 28, 2024
Modification: County of Alameda v. Alameda County Taxpayers' Assn., Inc.
Despite involvement of certain government officials, voter tax initiative, passed by simple majority, was valid. 		Tax 1DCA/5 Feb. 27, 2024
Mojave Pistachios, LLC v. Superior Court (Indian Wells Valley Groundwater Authority
Since the pay-first rule applies to challenges to fees imposed by groundwater sustainability agency, demurrer was appropriate where pistachio grower failed to pay replenishment fee before filing suit. 		Tax 4DCA/3 Feb. 19, 2024
County of Alameda v. Alameda County Taxpayers' Assn., Inc.
Despite involvement of certain government officials, voter tax initiative, passed by simple majority, was valid. 		Tax 1DCA/5 Jan. 31, 2024
Greenspan v. County of Los Angeles
Los Angeles County incorrectly calculated value of property after new construction because it did not reduce the value for structures that were removed. 		Tax 2DCA/4 Dec. 26, 2023
Stettner v. Mercedes-Benz Financial Services USA, LLC
Consumers fighting tax fees assessed after vehicle lease's termination were required to exhaust their administrative remedies prior to filing suit. 		Tax 3DCA Dec. 22, 2023
One Technologies LLC v. Franchise Tax Board
Because all aspects of Proposition 39's initiative dealt with its purpose of funding clean energy jobs, it did not violate the single-subject rule for ballot initiatives. 		Tax 2DCA/1 Oct. 25, 2023
FlightSafety International v. Los Angeles County Assessment Appeals Bd.
Trial court did not err in denying tax petitioner's writ request because tax petitioner had a viable, procedural process that writ relief would circumvent. 		Tax 2DCA/8 Oct. 24, 2023
Paramount Pictures Corp. v. County of Los Angeles
Los Angeles County Assessment Appeals Board did not commit methodological error in rejecting Paramount's property tax valuation that used the income approach rather than the recommended cost approach. 		Tax 2DCA/4 Oct. 2, 2023
Modification: SHR St. Francis, LLC v. City and County of San Francisco
Hotel's valuation for property tax reassessment should not have included intangible assets such as in-room movies and laundry services. 		Tax 1DCA/5 Sep. 15, 2023
SHR St. Francis, LLC v. City and County of San Francisco
Hotel's valuation for property tax reassessment should not have included intangible assets such as in-room movies and laundry services. 		Tax 1DCA/5 Aug. 21, 2023
Tarpey v. U.S.
Organization of tax-avoidance scheme was activity giving rise to tax penalties assessed by the IRS equal to 50 percent of the gross income from the scheme. 		Tax 9th Aug. 18, 2023
York v. U.S.
Former chief financial officer was liable for claim based on tax penalty for unpaid payroll taxes where he had authority to pay taxes and recklessly disregarded whether they were paid. 		Tax 9th Aug. 14, 2023
Traiman v. Alameda Unified School Dist.
School district's qualified special tax was acceptable given that it was uniformly applied to all parcels regardless of the possible effect of different tax rates for larger parcels. 		Tax 1DCA/5 Aug. 7, 2023
Grace v. The Walt Disney Company
Disney benefited from a "City Subsidy" under Anaheim's Living Wage Ordinance since it received a rebate of a portion of the incremental tax revenues collected by the city. 		Tax 4DCA/3 Jul. 14, 2023
Keene-Stevens v. Commissioner of Internal Revenue
The Tax Court erred by accepting, in individual deficiency proceedings, the partnership losses that taxpayers claimed on unsigned, unfiled tax forms to offset their non-partnership income. 		Tax 9th Jul. 5, 2023
CSHV 1999 Harrison, LLC v. County of Alameda
Limited liability company formed by a state public retirement system for real estate investments was not a political subdivision of the State of California exempt from documentary transfer taxes. 		Tax 1DCA/1 Jun. 2, 2023
RAR2 Villa Marina Center CA SPE, Inc. v. County of Los Angeles
Neither laches nor the statutory scheme barred County Assessor from responding to owners' request for lower valuation with a recommendation that the property be assessed at an even higher value. 		Tax 2DCA/7 May 25, 2023
Polselli v. IRS
Lower courts correctly determined that petitioners could not move to quash IRS's summonses seeking their financial records because no notice was needed, pursuant to a statutory exception to the notice requirement. 		Tax USSC May 19, 2023
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