The Regents of the University of California (“Claimant”) leases a property located at 2800 Mitchell Drive, Walnut Creek, California (APN 143-040-103-2) from Castlerock I, LP. Based on Claimant’s exclusive use of the Property, it requested that the Assessor’s Office exempt the Property from ad valorem property taxes under a constitutional exemption for years 2011/2012 through 2018/19. [Cal. Const., art. XIII, sec. 3(d); Rev. & Tax. Code, §§ 202.2.] The Assessor’s Office granted the exemption for four years, tax years 2015/2016 through 2018/2019, which resulted in a refund for those tax years. [Rev. & Tax. Code, § 4831.] However, the Assessor’s Office was unable to apply the exemption for earlier tax years because the law does not permit the Assessor’s Office to make corrections to the roll that relate to the exemption more than four years after the date of the assessment being corrected. [Rev. & Tax. Code, § 4831.]   
  
On May 31, 2019, Claimant submitted a Claim for Refund to the Board of Supervisors in the amount of $132,384.24 for property taxes paid for tax years 2011/2012 through 2014/2015. A four-year statute of limitations for claims for refunds runs from the date that the taxes that are sought to be refunded were paid for the Property. Because all of the property taxes at issue were paid more than 4 years before the claim was made on May 31, 2019, the claim as it relates to all of the tax years at issue is untimely. [Rev. & Tax. Code, § 5097(a)(2).]   
  
Additionally, the Claim for Refund does not appear to have been verified by “the person who paid the tax, his or her guardian, executor, trustee, or administrator.” For this additional reason, it does not meet the requirements of a claim for refund. (Rev. & Tax Code, § 5097(a)(1).)   
  
The Claim for Refund was also processed as a claim under the Government Claims Act. On September 10, 2019, the claim was denied as untimely under that Act.  

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