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  5. 129 Cal.Rptr.2d 107 (2002)
 

GENEVA TOWERS LTD. PARTNERSHIP v. CITY AND CTY. OF SAN FRANCISCO

No. S090136.

129 Cal.Rptr.2d 107 (2002)

29 Cal.4th 769

60 P.3d 692

GENEVA TOWERS LIMITED PARTNERSHIP, Plaintiff and Appellant, v. CITY AND COUNTY OF SAN FRANCISCO, Defendant and Respondent.

Supreme Court of California.

January 9, 2003.

Attorney(s) appearing for the Case

Divelbiss, Divelbiss & Bonzell, Robert Owen Divelbiss, Mark J. Divelbiss, Oakland; and Robert S. Beach, for Plaintiff and Appellant.

Bewley, Lassleben & Miller, Jeffrey S. Baird, Whittier, and Joseph A. Vinatieri as Amici Curiae on behalf of Plaintiff and Appellant.

Dennis J. Herrera and Louise H. Renne, City Attorneys, Patrick J. Mahoney, Jeffrey I. Margolis, Julie Van Nostern, Ellen Forman, Joseph M. Quinn and Owen Martikan, Deputy City Attorneys, for Defendant and Respondent.

Ruth Sorensen, Alturas, for California State Association of Counties as Amicus Curiae on behalf of Defendant and Respondent.

Bill Lockyer, Attorney General, Timothy G. Laddish, Assistant Attorney General; and David H. Levine for California State Board of Equalization and California Franchise Tax Board as Amici Curiae on behalf of Defendant and Respondent.

MORENO, J.

In this case, we consider what statute of limitations applies when a county or city fails to act upon a claim for refund of property taxes within six months and the taxpayer elects under Revenue and Taxation Code section 5141, subdivision (b) to "consider the claim rejected and bring an action" in superior court. For the reasons that follow, we conclude that the applicable statute of limitations is the six-month period set forth in Revenue and Taxation...

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