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JPMORGAN CHASE BANK, N.A. v. CITY AND COUNTY OF SAN FRANCISCO

No. A118806.

174 Cal.App.4th 1201 (2009)

JPMORGAN CHASE BANK, N.A., as Trustee, etc., Plaintiff and Appellant, v. CITY AND COUNTY OF SAN FRANCISCO et al., Defendants and Respondents.

Court of Appeals of California, First District, Division Five.

June 11, 2009.

Attorney(s) appearing for the Case

Fulbright & Jaworski, Robert W. Fischer and Spencer Persson for Plaintiff and Appellant.

Dennis J. Herrera, City Attorney, Julie Van Nostern, Chief Tax Attorney, James M. Emery, Peter J. Keith and Michael Slatter, Deputy City Attorneys, for Defendants and Respondents.

OPINION

NEEDHAM, J.—

Revenue and Taxation Code section 50971 provides that a taxpayer seeking a refund of property taxes must file a verified claim within four years after making the payment of the disputed tax unless an alternative period triggered by circumstances not relevant here applies. Appellant JPMorgan Chase Bank, N.A., as Trustee for the IBM Personal...

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