What is the test for determining whether a property owner has been paying taxes on the property described in his deed as "unimproved land"?

California, United States of America


The following excerpt is from Degann v. Hunanyan, B238685 (Cal. App. 2013):

We are guided by Sorensen v. Costa, supra, 32 Cal.2d 453. There, the court found the adverse claimant had in fact been paying taxes on the house he occupied, not on the "unimproved land" described in his deed; it relied on evidence of a mistaken description in the tax assessment rolls, which established that the claimant and his predecessors "not only thought that they were paying taxes on the land occupied but in fact paid taxes actually assessed against such lands." (Id. at p. 466.) The court elaborated: "There is no question that a person claiming title by adverse possession must show that he and his

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