Laws, Regulations & Annotations

Property Taxes Law Guide – Revision 2014

Property Tax Annotations

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Annotation 220.0525

220.0525 Partnership/Control. The ABC Partnership is owned by the XY Partnership (64 percent), X as an individual (20 percent), and X and his wife as co-owners (16 percent). X and Y each have a 50 percent interest in the XY Partnership.

The XY Partnership is terminated by Y's death, and X receives his 50 percent interest (32 percent interest in ABC Partnership) which, when combined with his individual 20 percent interest and 8 percent interest (half of the 16 percent owned with his wife), increases his ownership interest in the ABC Partnership to 60 percent. A change in control has occurred under Revenue and Taxation Code section 64(c), resulting in a change in ownership of the property owned by the ABC Partnership. The result would be different if X had already acquired control of ABC Partnership by owning more than 50 percent of the XY Partnership at the time of Y's death. C 5/18/1989; C 1/22/1999.