Steinhart v. County of Los Angeles (California Supreme Court, February 4, 2010)
Summary. Trustor established a revocable trust, named herself trustee and the sole beneficiary, and transferred her residence into the trust. When the trustor died the trust became irrevocable, provided the trustor's sister with a life estate in the residence, and named siblings as beneficiaries. The County of Los Angeles reassessed the real property for property tax purposes. The sister argued that since she received a life estate, there should be no reassessment for property tax purposes. The California Supreme Court held that at the time that the trust becomes irrevocable, a change in ownership occurs unless the trustor remains or becomes the sole beneficiary or unless otherwise excluded from change in ownership by other statutory rules.