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  5. 190 Cal.App.3d 1611 (1987)
 

SAV-ON DRUGS, INC. v. COUNTY OF ORANGE

Docket No. G003296.

190 Cal.App.3d 1611 (1987)

236 Cal. Rptr. 100

SAV-ON DRUGS, INC., et al., Plaintiffs and Appellants, v. COUNTY OF ORANGE et al., Defendants and Respondents.

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

April 10, 1987.

Attorney(s) appearing for the Case

COUNSEL

Baker, Ancel, Morris & Hruby, Mark G. Ancel and Raymond R. Hruby for Plaintiffs and Appellants.

Ajalat & Polley, Charles R. Ajalat, Terry L. Polley and Richard J. Ayoob as Amici Curiae on behalf of Plaintiffs and Appellants.

Adrian Kuyper, County Counsel, and Richard D. Oviedo, Deputy County Counsel, for Defendants and Respondents.

John K. Van de Kamp, Attorney General, and Timothy G. Laddish, Deputy Attorney General, as Amici Curiae on behalf of Defendants and Respondents.

OPINION

CROSBY, J.

Under article XIII A of the California Constitution, increases in appraised values of taxable real property are severely restricted; but a change in ownership will permit reassessment. In this case we are called upon to decide whether a corporate merger constituted a "change of ownership," as that phrase is defined in the Revenue and Taxation Code and, if so, whether the Legislature's interpretation of article XIII...

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