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The main question is - WHEN the property tax in dispute were assessed?
See page 4 in following official publication
Statute of LimitationsSections 51.5 and 532 establish Statutes of Limitations on the assessor, which affect the assessability of property. Although a property itself is not exempt, an assessment must be made timely to be valid. Unless the assessee intentionally evades taxation, as discussed in sections 502, 503, and subdivision (c) of 51.5, an assessment must normally be made within four years of the assessment period in which the property escaped assessment or was underassessed.
Please be aware that under some circumstances the statute of limitation might be longer or might be not applied.
In your situation - most likely the statute of limitation is eight year statute of limitations assuming 25% penalty applies.
Then - we need to look into the statute of limitation on collection.
But the main question is when the taxes were assessed.
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