Facts: Residents of a mobilehome park formed a nonprofit corporation and purchased the park. Each resident owned a mobilehome and the exclusive right to occupy the space through membership in the corporation. A resident later sold their mobilehome and membership interest, triggering reassessment of the space sold. The County Assessor determined the value of the space by deducting the fair market value of the mobilehome from the total purchase price paid for the mobilehome and the membership.
Claim: The park corporation sought to have reassessment calculated by determining the value of each space as a fraction of the total value of the park, claiming the assessor’s method was not consistent with California law since the law identifies mobilehome park membership interests as fractional ownerships of the park.
Counter claim: The assessor claimed their appraisal method was permissible since California law only defines the mobilehome park spaces that require reassessment and does not mandate a specific method for assessing the value of those interests.
Holding: The California Supreme Court held the assessor’s method was permitted since California law merely defines the mobilehome park membership interests to be reassessed upon a sale and does not mandate any particular method for determining the value of mobilehome park spaces. [Holland v. Assessment Appeals Board No. 1 (January 23, 2014) _C4th_]