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FIRST AMERICAN COMMERCIAL REAL ESTATE SERVICES, INC. v. COUNTY OF SAN DIEGO

No. D057463.

196 Cal.App.4th 218 (2011)

FIRST AMERICAN COMMERICAL REAL ESTATE SERVICES, INC., Plaintiff and Respondent, v. COUNTY OF SAN DIEGO, Defendant and Appellant.

Court of Appeals of California, Fourth District, Division One.

As modified June 10, 2011.

Attorney(s) appearing for the Case

John J. Sansone and Thomas E. Montgomery , County Counsel, and Timothy M. Barry , Deputy County Counsel, for Defendant and Appellant.

Best Best & Krieger, Bruce W. Beach and Brooke Miller for Plaintiff and Respondent.

OPINION

IRION, J.—

County of San Diego (the County) appeals from a judgment ordering it, pursuant to Revenue and Taxation Code section 4985.2, subdivisions (a) and (b), to cancel and refund penalties paid by First American Commercial Real Estate Services, Inc. (First American), for late payment of real property taxes.1 As we will explain, First American did not

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