Property Tax Assessment Appeals

How Property Tax Assessment Appeals Boards Work

Local appeals boards are independent agencies, separate from the Assessor’s office, established to decide disputes between County Assessors and property owners. You aren’t required to have an attorney or agent represent you — but as the applicant, you must personally attend the hearing, or be represented by someone thoroughly familiar with the facts of your appeal and the appeal process, including the Local Rules of the Board. If a representative appears on your behalf, you’ll need to provide written authorization before the hearing.

With proper evidence, an Appeals Board can lower, raise, or confirm a property’s assessed value, remove a penalty assessment imposed by the Assessor, or reverse a change-in-ownership or new-construction reassessment. What it cannot do: reduce your assessed value simply because you’re paying more than your neighbor, remove penalties or interest for late tax payment, reduce your taxes because you can’t afford them, set tax rates or levy taxes, grant or deny exemptions, extend filing periods, change another appeals board’s decision, or rehear an issue already decided.

Property Tax Assessment Appeals for a Decline in Value

If you believe your property’s market value has dropped below its assessed value, you can file a “decline in value” appeal for the current year. Under Revenue and Taxation Code §1603, the regular filing period runs July 2 through September 15 in counties where the Assessor mails assessment notices by August 1, or July 2 through November 30 in counties that don’t. Missing this window means losing your right to appeal that year’s assessment entirely — there’s no extension.

Your appeal must be based on the property’s market value as of January 1 of the assessment year — not the value on the date you actually file. If your appeal succeeds, the new assessed value applies to the tax year you appealed, but it doesn’t automatically carry forward. The Assessor reviews the property’s value annually once a decline has been established, comparing current market value against the base year value (adjusted for inflation), and assesses at whichever figure is lower.

Base Year Value Appeals

Property tax assessment appeals aren’t limited to disputes over current market value — you can also appeal the “base year value” itself. That concept comes from Proposition 13. Every property’s original base year value was set under Prop 13, and it stays the same unless a triggering event occurs — most commonly a change in ownership or completed new construction, either of which resets the base year value to the property’s market value at that time. If new construction affects only part of a property (adding a room, for example), only that portion gets a new base year value — the rest of the property keeps its existing one. Any base year value can be appealed if the property owner disagrees with it.

Calamity Reassessment Appeals

Property tax assessment appeals also cover disaster-related reassessments. When a property is damaged or destroyed through no fault of the owner — a natural disaster or other “calamity” — an Assessor’s appraiser determines the property’s market value before and after the damage, and the resulting percentage loss is applied to the assessed value for a refund (land value stays unchanged). If you disagree with the Assessor’s post-calamity value, you must file your appeal within six months of the notice’s mailing or postmark date, whichever is later.

Escape Assessments and Property Tax Assessment Appeals

Escape assessments correct for events — commonly new construction — that happened in a prior year but weren’t discovered by the Assessor in time. An escape assessment can roll a correction back to that earlier year. If you want to appeal an escape assessment, you must file within 60 days of the mailing date printed on the assessment notice, or the postmark date of the notice or tax bill, whichever is later.

Building Your Case: Evidence in Property Tax Assessment Appeals

Winning property tax assessment appeals comes down to evidence. An appeals board can only consider evidence you and the Assessor actually present at the hearing — not anything attached to your application or discussed with the Assessor’s office beforehand unless it’s also presented at the hearing itself.

Appraisers, including the Assessor, generally rely on three approaches to value: comparable sales of similar property, replacement cost less depreciation, and the income approach where applicable. In most residential appeals, comparable sales are the most reliable evidence — but simply listing sold properties without a detailed analysis of how they actually compare is a weak strategy. There’s also a legal age restriction on how old comparable sales evidence can be.

The burden of proof falls on the Assessor if the property is an owner-occupied single-family home; for every other property type, the burden falls on the owner. Either way, expect the Assessor to come prepared.

You can request a written summary of the facts and evidence the board relied on in reaching its decision. These “findings of fact” matter if the board rules against you and you want to appeal further, up through Superior Court.

Basic Terminology

• Base Year Value — the full cash value (market value) of a property on the date it changed ownership, or the full cash value of newly constructed property on the date construction was completed.
• Change in Ownership — transfer of a present interest in real property, including beneficial use, substantially equal in value to the fee interest.
• Escape Assessment — an assessment for an event, like a change in ownership or new construction, that occurred in a prior year but wasn’t discovered by the Assessor in time.
• Lien Date — 12:01 a.m. on January 1, the date property taxes attach as a lien and the date used to value property for that tax year.
• Market Value — the taxable value of a property, usually the sale price at purchase — though it may differ if the property came from a foreclosure, REO, auction, or probate sale.
• Penalty Assessment — an assessment imposed for failing to file a required property statement or change-of-ownership statement, added on top of the normal assessment.
• Supplemental Assessment — an assessment triggered by a change in ownership or completed new construction occurring after the January 1 lien date, billed separately and becoming its own lien on the property.

Related Articles

Holding Title to Real Property
Incorrect Deeds
The Escrow Process
Special Use Appraisals

Disclaimer: Every situation is different and particular facts may vary thereby changing or altering a possible course of action or conclusion. The information contained herein is intended to be general in nature as laws vary between federal, state, counties, and municipalities and therefore may not apply to any given matter. This information is not intended to be legal advice or relied upon as a legal opinion, course of action, accounting, tax or other professional service. You should consult the proper legal or professional advisor knowledgeable in the area that pertains to your particular situation.