AB 2172

AB2172:v96#DOCUMENT

Bill Start

CALIFORNIA LEGISLATURE— 2025–2026 REGULAR SESSION

Assembly Bill

No. 2172

An act to add and repeal Sections 1620.5 and 1622.3 of the Revenue and Taxation Code, relating to taxation.

LEGISLATIVE COUNSEL'S DIGEST

AB 2172, as amended, Gipson. Property taxation: county assessment appeals boards: assessment appeals commissioners.

Existing property tax law authorizes a county board of supervisors to create assessment appeals boards for the county to equalize the valuation of taxable property within the county for purposes of taxation. Existing property tax law requires an assessment appeals board to consist of 3 members or of 5 members acting as a 3-member panel, selected as specified. Existing law also sets forth minimum qualifications for a member of an assessment appeals board.

This bill, commencing January 1, 2027, and until January 1, 2034, would authorize the county board of supervisors of a county containing a population of 500,000 or more to alternatively provide by ordinance that all any property tax assessment appeals in the county may be heard and decided by a single-member appeals board, the single member of which would be known as an assessment appeals commissioner. The bill would set forth minimum qualifications for the commissioner, as specified. The bill would require the State Board of Equalization to adopt rules and guidelines necessary to ensure consistent hearing procedures, public access, and decisionmaking standards for these commissioners. The bill would prohibit a commissioner from hearing any new appeals after December 31, 2031, but would permit the commissioner to continue to hear and decide appeals received after January 1, 2027, but on or before December 31, 2031, following December 31, 2031. This bill would additionally require, if a county appoints commissioners to hear and decide assessment appeals, the county to provide a process by which the appellant may object to their appeal being heard and decided by an assessment appeals commissioner. The board would require the county, in the case that an appellant does not make that objection, to ensure the appeal is heard by a 3- or 5-member board.

This bill would specify that, for purposes of implementing the bill’s provisions with respect to other provisions relating to assessment appeals boards, a reference to an assessment appeals board also includes a single-member appeals board, as applicable, and a reference to member means a commissioner with respect to a single-member appeals board. The bill would make related findings and declarations.

Digest Key

Vote: MAJORITY Appropriation: NO Fiscal Committee: YES Local Program: NO

Bill Text

The people of the State of California do enact as follows:

SECTION 1.

The Legislature finds and declares all of the following:

(a) Assessment appeals boards play a critical role in ensuring fairness and uniformity in the property tax system by providing independent, quasi-judicial review of assessment disputes.

(b) In large and complex counties, the increasing volume and technical complexity of property assessment appeals—particularly involving income-producing and commercial properties—require greater professional expertise and procedural efficiency.

(c) Authorizing counties to appoint qualified assessment appeals commissioners, in lieu of three-member panels, will increase the timeliness, consistency, and legal rigor of property tax appeals determinations while preserving due process and public accountability.

(d) This act is intended to supplement, not replace, the authority of counties to appoint traditional, three-member assessment appeals boards under existing law.

SEC. 2.

Section 1620.5 is added to the Revenue and Taxation Code, to read:

1620.5.

(a) For purposes of this article in implementing Section 1622.3, both of the following shall apply:

(1) “Assessment appeals board” shall also include a single-member appeals board, as applicable.

(2) “Member,” when used to refer to a member of a three- or five-member assessment appeals board, shall mean a “commissioner,” with respect to a single-member appeals board.

(b) This section shall be operative only until January 1, 2034, and as of that date is repealed.

SEC. 3.

Section 1622.3 is added to the Revenue and Taxation Code, to read:

1622.3.

(a) As an alternative to the selection procedures established in Section 1622 and Section 1622.1, commencing January 1, 2027, and before January 1, 2032, the county board of supervisors of a county containing a population of 500,000 or more may, by ordinance, provide that all any property tax assessment appeals in the county may be heard and decided by a single-member appeals board, the single member of which shall be known as an assessment appeals commissioner. A commissioner appointed pursuant to this subdivision shall exercise all powers and duties of an assessment appeals board provided in this part. The qualifications for the commissioner shall be those set forth in Sections 1624, 1624.01, 1624.02, and 1624.05, in addition to those set forth in subdivision (b). An assessment appeals commissioner shall not hear and decide a property tax assessment if an appellant has filed an objection pursuant to subdivision (e).

(b) An assessment appeals commissioner appointed pursuant to subdivision (a) shall meet all of the following minimum qualifications:

(1) Possesses one of the following qualifications:

(A) A certified public accountant with experience in the appraisal or valuation of real property or business personal property.

(B) A licensed real estate broker holding one of the following professional designations:

(i) Certified commercial investment member (CCIM).

(ii) Certified real estate brokerage manager (CRB).

(iii) Certified residential specialist (CRS).

(iv) Graduate Realtor Institute (GRI).

(v) A comparable designation evidencing specialization in commercial or investment real estate.

(C) A real property appraiser holding the Member Appraisal Institute (MAI) designation or a comparable designation evidencing experience in the valuation of complex income-producing property.

(D) A personal property appraiser holding an Accredited Senior Appraiser (ASA) designation from the American Society of Appraisers or a comparable designation.

(E) An attorney with experience in the valuation of complex, income-producing, and business property.

(F) An individual with experience comparable to that described in subparagraphs (A) to (E), inclusive, as determined by the appointing authority.

(2) Has demonstrated ability to conduct fair and impartial hearings and to prepare written findings of fact and conclusions of law.

(c) A county that elects to appoint an assessment appeals commissioner pursuant to subdivision (a) may also authorize, by ordinance, the appointment of one or more alternate commissioners who meet the same qualifications as the commissioner. The alternate commissioners shall serve in the absence or disqualification of the regular commissioner.

(d) This section shall not be construed to limit the authority of a county to do either of the following:

(1) Establish multiple assessment appeals boards, whether composed of three members, five members acting as three-member panels, or a single commissioner.

(2) Appoint alternate members pursuant to this article.

(e) If a county appoints an assessment appeals commissioner pursuant to this section to adjudicate property tax appeals, the county shall provide a process by which the appellant may object to their appeal being heard and decided by an assessment appeals commissioner. Upon receipt of an objection, the county shall ensure the appeal is heard and decided by a three- or five-member assessment appeals board, as appropriate.

(f) The State Board of Equalization shall adopt rules and guidelines necessary to ensure consistent hearing procedures, public access, and decisionmaking standards for assessment appeals commissioners appointed pursuant to subdivision (b).

(g) The assessment appeals commissioner shall not hear any new appeals after December 31, 2031. However, the commissioner may continue to hear and decide appeals received after January 1, 2027, but on or before December 31, 2031, following December 31, 2031, in accordance with this part.

(h) This section shall be operative only until January 1, 2034, and as of that date is repealed.