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Assessment Appeals Board hears Penn Family Trust dispute over reassessment after trustee's death
Summary
The board heard competing presentations about whether the death of the last surviving trustor in October 2019 triggered a change in ownership that led to an escape assessment; the assessor argued the trust became irrevocable at death and beneficiaries received present beneficial interests, while the successor trustee said the property remained in trust. The board took the matter into closed deliberation.
The Assessment Appeals Board heard a contested appeal from the Ventura County Assessor's Office alleging an escape assessment after the death of a trustor.
The assessor presented the legal and recorded document history: Edwin M. and Constance M. Panchal bought the subject parcel in 1973, later placed it in a revocable family trust, and retained beneficial interest until Constance Panchal's death on Oct. 30, 2019. The assessor argued that when the last surviving trustor died the trust became irrevocable for property‑tax purposes and present beneficial interest passed to beneficiaries — a transfer that, under the Revenue and Taxation Code and related property tax rules, constitutes a change in ownership and triggers reassessment. The assessor noted a later recorded conveyance to an unrelated buyer on Sept. 29, 2023, and said a parent‑to‑child (Prop. 58) exclusion filed Nov. 7, 2025, was untimely under statute.
Successor trustee Steven (identifying himself as successor trustee of the Penn Family Trust) told the board no deed was recorded on Constance Panchal's death, that no monetary consideration changed hands and that the family intended the property to remain in trust. He asked the board to invalidate the escape assessment.
The assessor pointed to statutory provisions on revocable trusts and dates of change in ownership and noted the assessor mailed the escape assessment notice on Aug. 16, 2024. The assessor also cited Revenue and Taxation Code sections and property tax rules establishing that a trust that becomes irrevocable on the death of the trustor can trigger a reassessment event when present beneficial interest transfers.
After closing arguments the board said it would deliberate in closed session and return a written decision with findings of fact. The clerk confirmed payment for a request for findings had been received.
Key quotes: The assessor summarized the office position: "The transfer of the property upon Constance M.'s death was determined to constitute a change in ownership." The successor trustee told the board: "No money or other valuable considerations changed hands and no deed was recorded upon the death of my mother," and asked the board to invalidate the assessment.
What happens next: The board moved into closed session to deliberate and will issue a decision and findings on whether reassessment was proper and whether the parent‑to‑child exclusion or other statutory relief applies.
