California Property Tax Appeal Guide: The Complete Professional Reference

Unlike Texas, California doesn't require a specific license to represent property owners in assessment appeals. Anyone can serve as an authorized agent with written permission. But that doesn't mean the work is simple.

California's property tax system—built on Proposition 13—is fundamentally different from every other state. Understanding its nuances is the difference between winning appeals and wasting everyone's time.

This guide covers everything you need to know to effectively challenge property tax assessments in California. Consider it your desk reference for the Golden State's unique assessment appeal process.

Let's get into it.

What's Inside This Study Guide

1. Part 1 (This Page): Representation Rules, Proposition 13, Proposition 8
2. Part 2: Assessment Types, Valuation Methods, Appeal Process
3. Part 3: Deadlines, Exemptions, Building Your Case, Hearing Prep
4. Part 4: Key Statutes, County Variations, Practice Scenarios, Resources

1. Who Can Represent Property Owners in California

California takes a more open approach to property tax representation than Texas. Here's who can file and represent property owners at Assessment Appeals Board hearings:

No Authorization Required

• The property owner (applicant)
• Spouse or registered domestic partner
• Parent or child of the owner
• Co-owners of the property
• California-licensed attorneys

Written Authorization Required

Anyone else representing the property owner—including professional property tax agents—must have written authorization filed with the Assessment Appeals Board before the hearing.

Key points about authorization:

• Must be signed by the property owner
• Can be included on the Assessment Appeal Application (Form BOE-305-AH)
• Or filed separately using the county's Authorization of Agent form
• Typically valid for 4 years unless revoked earlier
• Each county may have specific requirements—check with the Clerk of the Board

Important: While no license is required, you must still comply with Business and Professions Code regulations if you're providing services for compensation. Misrepresentation or unauthorized practice of law can result in penalties.

2. The Foundation: Proposition 13 Explained

Proposition 13, passed by California voters in June 1978, fundamentally changed property taxation in the state. Understanding Prop 13 is essential—it governs how nearly every property in California is assessed.

The Three Pillars of Proposition 13

Pillar	Rule	Impact
1% Tax Rate Cap	Property taxes limited to 1% of assessed value (plus voter-approved bonds)	Predictable tax rates across the state
Base Year Value	Properties assessed at purchase price (or 1975 value for pre-1975 owners)	Long-term owners pay less than new buyers
2% Annual Cap	Assessed value cannot increase more than 2% per year (or CPI, whichever is less)	Protection from market volatility

Base Year Value

The base year value is established when:

• Change in Ownership occurs—property reassessed to current market value
• New Construction is completed—improvements assessed at current market value
• Pre-1975 Properties—base year value is the 1975 assessed value

Factored Base Year Value (FBYV)

Each year, the Assessor multiplies the base year value by an inflation factor (not to exceed 2%). This creates the "factored base year value"—the maximum assessment under Prop 13.

Formula:

Current FBYV = Base Year Value × (1 + inflation factor)^years since base year

Example: A home purchased in 2015 for $500,000 with maximum 2% annual increases would have a 2025 FBYV of approximately $609,497.

What Triggers Reassessment

Event	Result	Notes
Sale/Transfer	Full reassessment to market value	New base year established
New Construction	Value of improvements added	Land base year value unchanged
Parent-Child Transfer (Prop 19)	Limited exclusion up to $1M for primary residence/family farm	Effective Feb 16, 2021
Grandparent-Grandchild Transfer	Same as parent-child if parents deceased	Under Prop 19 rules

3. Proposition 8: Decline-in-Value Reductions

Proposition 8 (passed November 1978) provides the mechanism for temporary assessment reductions when market value drops below the Prop 13 value.

How Prop 8 Works

Under Prop 8, the Assessor must enroll the lesser of:

• The property's factored base year value (Prop 13 value), OR
• The property's current market value as of January 1 (lien date)

This is codified in Revenue and Taxation Code Section 51(a)(2).

Key Characteristics of Prop 8 Reductions

Feature	Description
Temporary	Reduced value applies only while market value remains below FBYV
No 2% Cap on Increases	Properties in Prop 8 status can increase more than 2% annually until they reach FBYV
Annual Review	Assessor reviews each January 1 to determine if Prop 8 status continues
Cap at FBYV	Even if market value rises above FBYV, assessment never exceeds FBYV

Appeal Strategy

When market values decline, many Assessors proactively reduce values. However, if your client's property hasn't been reduced—or hasn't been reduced enough—this is prime appeal territory.

Key evidence for Prop 8 appeals:

• Comparable sales within 90 days after the lien date (RTC §402.5)
• Evidence of property condition issues
• Neighborhood decline factors
• Income approach for commercial properties

4. Types of Assessments You'll Encounter

Regular Assessment (Annual Roll)

The assessed value as of January 1 (the "lien date"). This appears on the annual assessment roll and reflects either:

• Factored base year value, or
• Prop 8 reduced value (if market value is lower)

Supplemental Assessment

Triggered by change in ownership or new construction, this captures the difference between the old assessed value and the new base year value, prorated for the portion of the fiscal year remaining.

Example: Home purchased July 1 for $800,000, previous assessed value was $400,000. Supplemental assessment = $400,000 × (9/12) = $300,000 additional taxable value for that fiscal year.

Escape Assessment

An assessment that "escaped" the regular roll—meaning a change in ownership or new construction wasn't captured. Assessors can go back up to 4 years (8 years for fraud or willful misrepresentation).

Roll Correction

Corrections to the assessment roll for clerical errors, assessor errors, or applicant requests under RTC §25.25 (similar to Texas, but different procedures).

Penalty Assessment

Penalties for failing to file required statements:

• Change in Ownership Statement (COS) – 10% penalty if not filed within 90 days
• Business Property Statement (571-L) – 10% penalty if not filed by deadline

5. The Three Approaches to Value

California assessors—and you as an appellant—use three primary valuation methodologies. Understanding when to apply each approach is crucial.

Market (Sales Comparison) Approach

The most common approach for residential property. Compare subject property to similar properties that recently sold.

Factor	Adjustment Direction
Comp has more bedrooms	Subtract from comp price
Subject has pool, comp doesn't	Add to comp price
Comp sold 6 months before lien date	Time adjustment (market trend)
Comp in better location	Subtract from comp price

Critical Rule: Per RTC §402.5, the Assessment Appeals Board cannot consider comparable sales dated more than 90 days AFTER the lien date (January 1). Sales before the lien date are acceptable.

Cost Approach

Best for newer properties or unique properties with limited comparable sales. Calculate reproduction/replacement cost minus depreciation plus land value.

Formula:

Value = Land Value + (Replacement Cost New – Accumulated Depreciation)

Types of depreciation:

• Physical: Wear and tear, deferred maintenance
• Functional: Outdated design, poor floor plan
• External/Economic: Location factors, market conditions

Income Approach

Primary method for commercial and rental properties. Two main techniques:

Direct Capitalization:

Value = Net Operating Income ÷ Capitalization Rate

Discounted Cash Flow (DCF):

Projects future income and discounts to present value—used for properties with irregular income streams.

Key terms:

• Gross Potential Income (GPI): Maximum rent if fully leased
• Effective Gross Income (EGI): GPI minus vacancy/collection losses
• Net Operating Income (NOI): EGI minus operating expenses
• Capitalization Rate: Rate of return investors require

6. The Assessment Appeals Process Step-by-Step

Step 1: Informal Review with Assessor

Before filing a formal appeal, contact the County Assessor's office. Many disputes are resolved informally without a hearing. The Assessor can:

• Explain the basis for the assessment
• Review your evidence
• Agree to reduce the assessment if warranted

Step 2: File Assessment Appeal Application

If informal resolution fails, file Form BOE-305-AH (Assessment Appeal Application) with the Clerk of the Assessment Appeals Board in the county where the property is located.

Required information:

• Assessor's Parcel Number (APN)
• Current assessed value
• Your opinion of value
• Basis for your opinion (comparable sales, income data, etc.)
• Agent authorization (if applicable)

Step 3: Exchange of Information

Per RTC §1606 and Property Tax Rule 305.1:

• Either party can request an exchange of valuation information
• Must occur at least 30 days before the hearing
• The requesting party must provide their information first

Step 4: Hearing Notice

The Clerk will send a hearing notice at least 45 days before your scheduled hearing. You must return the "Hearing Date Confirmation Notice" at least 21-30 days prior (varies by county).

Step 5: The Hearing

Hearings occur before either:

• Assessment Appeals Board (AAB): 3-member panel appointed by Board of Supervisors
• Hearing Officer: Single officer for properties under $500,000 (or single-family residences)

The hearing is quasi-judicial—less formal than court but structured. Both sides present evidence; the board/officer decides based on preponderance of evidence.

Step 6: Board Decision

The board may:

• Reduce the assessed value (most common successful outcome)
• Confirm the Assessor's value
• Increase the assessed value (yes, this can happen—be prepared)

Step 7: Further Appeal Options

If you disagree with the AAB decision:

• Request Findings of Fact: Must be requested BEFORE the hearing begins and requires a fee
• Superior Court: File within 6 months of AAB decision (requires Findings of Fact)

California Appeal Process Flowchart

Step	Action	Timeline
1	Contact Assessor for informal review	Anytime before filing deadline
2	File BOE-305-AH application	By deadline (varies by assessment type)
3	Request/provide information exchange	30+ days before hearing
4	Receive hearing notice	45+ days before hearing
5	Return confirmation notice	21-30 days before hearing
6	Attend hearing, present evidence	Scheduled date
7	Receive decision	Within 2 years of application
8	Appeal to Superior Court (if needed)	Within 6 months of AAB decision

7. Critical Filing Deadlines

Assessment Type	Filing Deadline	Notes
Regular Assessment	July 2 – September 15 (most counties) or November 30 (some counties)	Check your county—LA County extends to November 30
Supplemental Assessment	60 days from notice mailing date	Also applies to base year value appeals
Escape Assessment	60 days from notice mailing date	Or from supplemental tax bill if no notice sent
Roll Correction	60 days from notice mailing date	For errors discovered mid-year
Calamity Reassessment	6 months from notice mailing date	For disaster-damaged properties
Penalty Assessment	60 days from notice mailing date	Burden of proof on Assessor

Critical: If the deadline falls on a weekend or legal holiday, the deadline extends to the next business day. Postmarks count—mail on the deadline date is timely.

California Property Tax Calendar

Date	Event
January 1	Lien date—property values determined as of this date
February 15	Exemption filing deadline (for full exemption)
April 1	Business property statement deadline (571-L)
July 1	Fiscal year begins; annual roll completed
July 2	Regular roll appeal filing period opens
September 15	Regular roll appeal deadline (most counties)
November 1	First installment tax bill due
November 30	Regular roll appeal deadline (LA County and others)
December 10	First installment delinquent after this date
February 1	Second installment tax bill due
April 10	Second installment delinquent after this date

8. Property Tax Exemptions

Homeowners' Exemption

A $7,000 reduction in assessed value for owner-occupied primary residences.

• Eligibility: Own and occupy as principal residence on January 1
• Filing: One-time filing; continues automatically
• Deadline: February 15 for full exemption (late claims receive 80%)
• Savings: Approximately $70/year (at 1% tax rate)

Disabled Veterans' Exemption

Substantial exemption for veterans with 100% service-connected disability.

Exemption Tier	2025 Amount	Income Limit
Basic Exemption	$175,298	No limit
Low-Income Exemption	$262,950	Household income under $78,718

Note: Amounts are adjusted annually for inflation. Basic exemption requires one-time filing; low-income exemption requires annual filing by February 15.

Veterans' Exemption

A $4,000 exemption for honorably discharged veterans—but most veterans won't qualify because:

• Asset limit: $5,000 (unmarried) or $10,000 (married)
• Homeowners typically exceed these limits
• Homeowners' Exemption ($7,000) provides greater benefit anyway

Senior/Disabled Property Tax Postponement

Not an exemption, but worth knowing: The State Controller's program allows eligible homeowners (seniors 62+, blind, or disabled) to defer property taxes if:

• Household income ≤ $45,000
• At least 40% equity in home
• Primary residence

Deferred taxes become a lien repaid when property sells or transfers.

Other Exemptions

• Church/Religious: Property used exclusively for religious worship
• Nonprofit/Welfare: Property used for charitable purposes (requires Organizational Clearance Certificate from BOE)
• Historical Property: Mills Act contracts can reduce assessments 40-60%

9. Building a Strong Appeal Case

For Decline-in-Value (Prop 8) Appeals

Best evidence:

• 3-5 comparable sales close to lien date (within 6 months before, 90 days after)
• Same neighborhood or comparable area
• Similar size, age, condition, features
• Adjustment grid showing how you arrived at indicated value

Supporting evidence:

• Photos showing property condition issues
• Repair estimates for deferred maintenance
• Documentation of external obsolescence (noise, traffic, neighborhood issues)
• Market trend data showing declining values

For Change in Ownership/New Construction Appeals

Common issues to challenge:

• Assessor used wrong purchase price (check for closing credits, personal property included)
• New construction value overstated (review building permits vs. actual costs)
• Property condition at time of sale not reflected
• Non-arms-length transaction treated as market sale

For Commercial Property Appeals

Income approach evidence:

• Actual rent rolls and lease abstracts
• Operating statements (2-3 years)
• Vacancy rates (actual and market)
• Comparable rental data
• Cap rate support from market transactions

What NOT to Argue

The Assessment Appeals Board cannot consider:

• "My taxes are too high" (rate is set by law)
• "My neighbor pays less" (different base year values are legal)
• "I can't afford my taxes" (hardship isn't grounds for reduction)
• Comparables sold more than 90 days after lien date

10. Preparing for the Hearing

Before the Hearing

• Request exchange of information (RTC §1606) to see Assessor's evidence
• Organize exhibits chronologically and number them
• Prepare 3-4 copies of all documents (Board, Assessor, yourself, file)
• Write a brief outline of your presentation
• Confirm hearing date and return required notices on time

At the Hearing

Order of presentation:

1. Applicant presents case first (unless Assessor is seeking increase or penalty assessment)
2. Assessor presents rebuttal
3. Applicant may rebut
4. Board asks questions
5. Closing statements

Tips for effective presentation:

• Be concise—boards hear many cases
• Lead with your strongest evidence
• Address comparables: why yours are better than Assessor's
• Stay professional; never argue with the board
• Answer questions directly

Burden of Proof

Applicant bears burden UNLESS:

• Penalty assessment (burden on Assessor)
• Owner-occupied single-family dwelling where applicant provided all required information
• Escape assessment where applicant filed required statements
• Non-enrollment of purchase price where applicant filed COS
• Assessor seeks value increase

Hearing Checklist

✓	Item
☐	Confirmation notice returned on time
☐	Information exchange completed (if requested)
☐	4 copies of all exhibits
☐	Exhibits numbered and organized
☐	Agent authorization filed (if applicable)
☐	Presentation outline prepared
☐	Findings of Fact requested (if preserving court appeal)
☐	Photo ID for check-in

11. Key Revenue and Taxation Code Sections

Section	Topic	Key Provisions
§51	Full Value / Prop 8	Requires enrollment of lesser of FBYV or current market value
§110	Full Cash Value Definition	Market value standard; arm's length transaction
§110.1	Purchase Price Presumption	Purchase price presumed to be full cash value if arm's length
§402.5	Comparable Sales Limit	Sales >90 days after lien date cannot be considered
§1601-1611	Assessment Appeals	Filing procedures, deadlines, board powers
§1606	Exchange of Information	Pre-hearing evidence exchange procedures
§1609.4	Value Increase Notice	Assessor must give advance notice if seeking increase
§1610.8	Board Findings	Board must find full cash value from evidence
§205.5	Disabled Veterans' Exemption	Eligibility and amounts
§218	Homeowners' Exemption	$7,000 exemption for owner-occupied residence

Constitutional Provisions

• Article XIII A: Proposition 13 provisions (1% rate, 2% cap, base year value)
• Article XIII, Section 4: Veterans and disabled veterans exemptions

Property Tax Rules (Title 18, CCR)

• Rule 305.1: Exchange of information procedures
• Rule 307: Evidence and burden of proof
• Rule 313: Assessor notification requirements

12. County-by-County Variations

California's 58 counties have different procedures. Key variations to check:

Variable	Typical Range
Regular Roll Filing Deadline	September 15 (most) or November 30 (LA, some others)
Filing Fee	$0 – $50+ (some counties charge per parcel)
Online Filing	Available in many counties; check individual county sites
Hearing Response Deadline	21-30 days before hearing (varies)
Hearing Officer Threshold	$500,000 or single-family residence (typical)

Major County Quick Reference

County	Filing Deadline	Filing Fee	Online Filing
Los Angeles	November 30	No fee	Yes
San Diego	November 30	No fee	Yes
Orange	November 30	No fee	Yes
San Francisco	September 15	No fee	Yes
Santa Clara	September 15	No fee	Yes
Alameda	September 15	No fee	Yes
Riverside	November 30	No fee	Yes
San Bernardino	December 1	$45/application	Yes

Always verify current procedures with the Clerk of the Board in each county.

13. Practice Scenarios

Scenario 1: Decline in Value

Facts: Client purchased home in 2018 for $750,000. Current FBYV is $867,000. Market value as of January 1, 2025 is estimated at $720,000 due to market conditions.

Question: What value should be on the roll?

Answer: $720,000 (current market value is less than FBYV, so Prop 8 applies)

Scenario 2: Appeal Timing

Facts: Client receives supplemental assessment notice dated July 15. When must they file an appeal?

Answer: Within 60 days of July 15 = September 13

Scenario 3: Comparable Sales

Facts: Appealing January 1, 2025 regular roll value. You have comparable sales from November 2024, February 2025, and May 2025.

Question: Which sales can the board consider?

Answer: November 2024 (before lien date—OK) and February 2025 (within 90 days after—OK). May 2025 is more than 90 days after January 1 and cannot be considered.

Scenario 4: Burden of Proof

Facts: Client appealing penalty assessment for late filing of Change in Ownership Statement.

Question: Who bears the burden of proof?

Answer: The Assessor bears the burden for penalty assessments.

Scenario 5: Exemption Choice

Facts: Client is a disabled veteran with 100% rating, household income $60,000, owns home worth $800,000.

Question: Which exemption provides greatest benefit?

Answer: Low-income Disabled Veterans' Exemption ($262,950 reduction) because income is below $78,718 limit. Far better than basic DV ($175,298) or Homeowners' ($7,000).

Scenario 6: Prop 8 Restoration

Facts: Property was reduced under Prop 8 to $500,000 in 2023. FBYV is $600,000. Market value rebounds to $580,000 in 2025.

Question: What is the 2025 assessed value?

Answer: $580,000. Properties in Prop 8 status are not limited to 2% increases—they can increase to market value until reaching FBYV.

Scenario 7: New Construction

Facts: Client owned home with base year value of $400,000 (FBYV $450,000). Added a $100,000 ADU in 2024.

Question: What is the new total assessed value?

Answer: $550,000 ($450,000 existing FBYV + $100,000 new construction). The ADU gets its own base year value; land value is unchanged.

14. Official Resources

California State Board of Equalization

• Property Taxes Homepage
• Publication 30: Residential Property Assessment Appeals
• Publication 29: California Property Tax Overview
• Property Tax Law Guide
• County Assessor Directory

Key Forms

• BOE-305-AH: Assessment Appeal Application
• BOE-261-G: Disabled Veterans' Exemption Claim
• BOE-266: Homeowners' Exemption Claim
• County-specific Authorization of Agent forms

Assessors' Handbook Sections

• AH 501: Basic Appraisal
• AH 502: Advanced Appraisal
• AH 505: Personal Property Assessment
• AH 510: Real Property Appraisal

Summary: California vs. Texas at a Glance

Factor	California	Texas
License Required	No (authorization only)	Yes (RPTC license)
Assessment Basis	Acquisition value (Prop 13)	Current market value
Annual Increase Cap	2% (or CPI, whichever less)	10% for homestead
Tax Rate	~1% + bonds	~2-3%+ (varies by jurisdiction)
Appeal Filing Window	July 2 – Sept 15 or Nov 30	May 15 (or 30 days from notice)
Lien Date	January 1	January 1
Appeal Body	Assessment Appeals Board	Appraisal Review Board (ARB)
Term Used	"Appeal"	"Protest"
Value Can Increase at Hearing	Yes	No (ARB cannot raise value)