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Cubberley Community Center

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Cubberley Community Center known locally as "Cubberley", is a community center in Palo Alto, California , that has been in operation since 1990. It is housed on the campus of the former Ellwood P. Cubberley High School . Space is available for rent by the hour, either one-time or on a regular basis for community related meetings, seminars, social events, dances, theatre performances, music rehearsals and athletic events.

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71-506: The Ellwood P. Cubberley High School opened in the Fall of 1956 and closed in 1979, as a result of budget cuts from California Proposition 13 (1978) . Cubberley High School is perhaps best known as the setting of Ron Jones' 1967 social experiment The Third Wave , helping to teach Fascism. The high school was named after Ellwood P. Cubberley , an influential authority in the development of institutionalized education. The 35-acre property belongs to

142-545: A campaign to overthrow the government. Tax resisters have been violent revolutionaries like John Adams and pacifist nonresistants like John Woolman ; communists like Karl Marx and capitalists like Vivien Kellems ; solitary anti-war activists like Ammon Hennacy and leaders of independence movements like Mahatma Gandhi. Leo Tolstoy , a Christian anarchist , urged government leaders to change their attitude to war and citizens to taxes: If only each King, Emperor, and President understood that his work of directing armies

213-551: A change of control or ownership of a legal entity causes a reassessment of its real property as well as the real property of entities that it controls. The application to commercial and rental property can lead to an advantage and profit margin for incumbent individuals or corporations who purchased property at a time when prices were low. This is in contrast to the initial campaign, where Jarvis argued that lowering property tax rates would cause landlords to pass savings onto renters, who were upset at their rapidly rising rents driven by

284-452: A change of ownership, such as when additions or new construction occur. The assessed value is also subject to reduction if the market value of the property declines below its assessed value, such as during a real estate slump. Reductions of property valuation were not provided for by Proposition 13 itself, but were made possible by the passage of Proposition 8 (Senate Constitutional Amendment No. 67) during 1978 that amended Proposition 13. Such

355-503: A consequence of Proposition 13, homeowners in California receive a property subsidy that increases the longer that they own their home. It has been described as a contributor to California's housing crisis , as its acquisition value system (where the assessed value of property is based on the date of its acquisition rather than current market value) incentivizes long-time homeowners to hold onto their properties rather than downsize , reducing

426-427: A form of tax resistance in which they reduce their income below the tax threshold by taking up a simple living lifestyle. These individuals believe that their government is engaged in immoral, unethical or destructive activities such as war, and that paying taxes inevitably funds these activities. These methods differ from tax evasion in that they stay within the tax laws, and they differ from tax avoidance in that

497-433: A maximum of 2% per year until, and unless, the property has a change of ownership. At the time of the change in ownership the low assessed value may be reassessed to complete current market value that will produce a new base year value for the property, but future assessments are likewise restricted to the 2% annual maximum increase of the new base year value. The property may be reassessed under certain conditions other than

568-766: A nearly two to one margin. It was upheld by the Supreme Court in 1992 in Nordlinger v. Hahn , 505 U.S. 1 (1992). Proposition 13 is embodied in Article XIII A of the Constitution of the State of California . The proposition decreased property taxes by assessing values at their 1976 value, limiting the rate of taxation to 1% of the assessed value, and restricting annual increases of assessed value to an inflation factor, not to exceed 2% per year. It prohibits reassessment of

639-440: A new base year value except in cases of (a) change in ownership, or (b) completion of new construction. These rules apply equally to all real estate, residential and commercial—whether owned by individuals or corporations. Significantly, the initiative also requires a two-thirds majority in both legislative houses for future increases of any state tax rates or amounts of revenue collected, including income tax rates. It also requires

710-463: A real estate slump and downward reassessments occurred during 2009 when the California State Board of Equalization announced an estimated reduction of property tax base year values due to negative inflation . The property tax in California is an ad valorem tax meaning that the tax assessed generally increases and decreases with the value of the property. In the year after Proposition 13

781-646: A resister might home-brew beer ; to avoid excise taxes on gasoline, a resister might take up cycling ; to avoid income tax, a resister may reduce their income below the tax threshold by embracing simple living or a freegan lifestyle. For example, British citizens pay no income tax if their income is below the personal allowance . In the US the equivalent tax-free annual income is the standard deduction , though many deductions and credits allow people to earn much more than this and still avoid income tax. Opposition to war has led some, such as Ammon Hennacy and Ellen Thomas, to

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852-588: A result of California's population growth, continued growth in state and local government spending, increasing housing demand, government restrictions on new developments and inflation. Due to severe inflation during the 1970s, reassessments of residential property increased property taxes so much, that some retired people could no longer afford to remain in homes they had purchased long before. A 2006 study published in Law & Society Review supported this explanation, reporting that older voters, homeowners, and voters expecting

923-402: A slight positive fiscal impact, as opposed to the position that housing does not "pay its own way". The trade association argues that this is because new homes are assessed at the value when they are first sold. Additionally, due to the higher cost of new homes, the trade association claims that new residents are more affluent and may provide more sales tax revenues and use less social services of

994-494: A sufficient number of signatures on a petition . Proposition 13 passed with roughly two-thirds of those who voted in favor and with the participation of around two-thirds of registered voters. After passage, it became article XIII A of the California Constitution. Under Proposition 13, the annual real estate tax on a parcel of property is limited to 1% of its assessed value. This "assessed value" may be increased only by

1065-409: A tax increase were more likely to vote for Proposition 13. Proposition 13 is not the only law in California designed to prevent tax-induced displacement. The California Tax Postponement Program, passed in 1977, ensures that “homeowners who are seniors, are blind, or have a disability to defer current-year property taxes on their principal residence if they meet certain criteria”. Another explanation

1136-444: A track, a grassy school "amphitheater," and a gym, now used as sites for public running, recreation, and community athletics respectively. Cubberley Community Center has been home to local interest organizations including; a ballroom dancing club, child care services, senior center, wildlife rescue organization, Palo Alto Vineyard Church, a Chinese reading room, kung fu classes, karate lessons, private artist studios, L’Ecole de Danse,

1207-486: A two-thirds (2/3) majority in both legislative houses for future increases of any state tax rates or amounts of revenue collected, including income tax rates and sales tax rates. Proposition 13 also requires two-thirds (2/3) voter approval for cities, counties, and special districts to impose special taxes. In Altadena Library District v. Bloodgood , 192 Cal. App. 3d 585 (June 1987), the California Court of Appeal for

1278-463: A two-thirds majority in local elections for local governments wishing to increase special taxes. (A "special tax" is a tax devoted specifically to a purpose: e.g. homelessness or road repair; money that does not go into a general fund.) Proposition 13 has been described as California's most famous and influential ballot measure; it received enormous publicity throughout the United States. Passage of

1349-480: A useful symbolic target, or because they are more easily resisted. For instance, in the United States, many tax resisters resist the telephone federal excise tax . The tax was initiated to pay for the Spanish–American War and has frequently been raised or extended by the government during times of war. This made it an attractive symbolic target as a " war tax ". Such refusal is relatively safe: because this tax

1420-430: A vote of 53–47%, and instead passed Proposition 13 with nearly 65% of the vote. A Los Angeles Times article published shortly following the passage of Proposition 13 supported the latter interpretation, stating: Tax revolt Tax resistance is the refusal to pay tax because of opposition to the government that is imposing the tax, or to government policy, or as opposition to taxation in itself . Tax resistance

1491-490: A vote of the public". Among these purposes were community services, fringe benefits, and child care. For example, before 1978, the North Orange County Community College District levied a special tax on all property owners in the district which funded a comprehensive health care plan generous enough to amount to an overall 4% increase in compensation for all employees. By severely curtailing

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1562-554: A way that creates inconvenience for the collector—for instance, by paying the entire amount in low-denomination coins. This last method is less effective in countries where small coins are legal tender only in limited amounts, allowing the tax authority legally to reject such payments; for example in England and Wales, 1p coins are legal tender only in amounts up to 20p. Other tax resisters change their lifestyles so that they owe less tax. For instance; to avoid consumption taxes on alcohol,

1633-510: Is Proposition 13 drew its impetus from the 1971 and 1976 California Supreme Court rulings in Serrano v. Priest , which somewhat equalized California school funding by redistributing local property taxes from wealthy to poor school districts. According to this explanation, property owners in affluent districts perceived that the taxes they paid were no longer benefiting their local schools, and chose to cap their taxes. A problem with this explanation

1704-430: Is a form of direct action and, if in violation of the tax regulations, also a form of civil disobedience . Tax resisters are distinct from " tax protesters ", who deny that the legal obligation to pay taxes exists or applies to them. Tax resisters may accept that some law commands them to pay taxes but they still choose to resist taxation. Examples of tax resistance campaigns include those advocating home rule , such as

1775-567: Is not an honourable and important duty, as his flatterers persuade him it is, but a bad and shameful act of preparation for murder—and if each private individual understood that the payment of taxes wherewith to hire and equip soldiers, and, above all, army-service itself, are not matters of indifference, but are bad and shameful actions by which he not only permits but participates in murder—then this power of Emperors, Kings, and Presidents, which now arouses our indignation, and which causes them to be murdered, would disappear of itself. As an example of

1846-512: Is that the Serrano decision and school finance equalization were popular among California voters. While Californians who voted for Proposition 13 were less likely than other voters to support school finance equalization, Proposition 13 supporters were not more likely to oppose the Serrano decision, and on average they were typically supportive of both the Serrano decision and of school finance equalization. A 2020 study by Joshua Mound published in

1917-411: Is true that California's government had grown. Between 1973 and 1977, California state and local government expenditures per $ 1,000 of personal income were 8.2% higher than the national norm. From 1949 to 1979, public sector employment in California outstripped employment growth in the private sector. By 1978, 14.7% of California's civilian work force were state and local government employees, almost double

1988-445: Is typically small, resistance very rarely triggers significant government retaliation. Phone companies will cooperate with such resisters by removing the excise tax from their phone bills and reporting their resistance to the government. The most dramatic and characteristic method of tax resistance is to refuse to pay a tax – either by quietly ignoring the tax bill or by openly declaring the refusal to pay. Some tax resisters resist only

2059-497: The Journal of Policy History challenged the idea that wealthy property owners' desire to cap their property taxes was the impetus for enacting Proposition 13, instead saying the "tax revolt" was rooted in lower and middle-income Americans' longstanding frustration with unfair and highly regressive tax distributions during the post-World War II decades. The study said pro-growth Kennedy-Johnson "Growth Liberals" cut federal income taxes in

2130-582: The California Legislative Analyst's Office found that property tax revenue to local governments was similarly volatile before and after the passage of Proposition 13. While Proposition 13 stabilized the base, prior to Proposition 13, governments would adjust the rate annually to counteract changes to the base. According to the California Building Industry Association , construction of a median priced house results in

2201-641: The Master Plan for Higher Education provided that junior colleges would be established within commuting distance of nearly all California residents, which required the founding of twenty-two new colleges on top of the sixty-four colleges already operating as of 1960. In 1967, the junior colleges were renamed " community colleges " and became part of the California Community Colleges system. Before Proposition 13, community college districts were able "to levy certain taxes for special purposes without

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2272-857: The Napoleonic wars , whilst the US federal government imposed their first income tax in the Revenue Act of 1861 to help pay for the American Civil War . Tax resisters come from a wide range of backgrounds with diverse ideologies and aims. For example, Henry David Thoreau and William Lloyd Garrison drew inspiration from the American Revolution and the stubborn pacifism of the Quakers . Some tax resisters refuse to pay tax because their conscience will not allow them to fund war, whilst others resist tax as part of

2343-923: The Palo Alto Chamber Orchestra and many more. The Friends of the Palo Alto Library holds used book sales at Cubberley on the second Saturday of every month and the following Sunday, at three locations on campus. The Cubberley Community Center once hosted rock shows by local bands and touring artists including Buffalo Springfield , Santana , William Penn and His Pals , Cake , Third Eye Blind , blink-182 , Daniel Tsai Band, and Frank Black . 37°25′04″N 122°06′27″W  /  37.417874°N 122.107544°W  / 37.417874; -122.107544 California Proposition 13 (1978) Mayoral elections: Mayoral elections: Mayoral elections: Mayoral elections: Mayoral elections: Mayoral elections: Proposition 13 (officially named

2414-744: The Palo Alto Unified School District (PAUSD) , and is leased to the City of Palo Alto. The larger remainder of this site, (approx. 39,000 square feet) was leased since 2002 to the Foothill-De Anza College District for the Middlefield Campus of Foothill College , a local community college. However, in 2016 this campus moved to Sunnyvale and with the loss of Foothill College as a tenent, this opened up more rentable space for other community-based organizations. The site boasts

2485-528: The People's Initiative to Limit Property Taxation ) is an amendment of the Constitution of California enacted during 1978, by means of the initiative process, to cap property taxes and limit property reassessments to when the property changes ownership, and to require a 2/3 majority for tax increases in the state legislature. The initiative was approved by California voters in a primary election on June 6, 1978, by

2556-535: The Salt March led by Mahatma Gandhi , and those promoting women's suffrage , such as the Women's Tax Resistance League . War tax resistance is the refusal to pay some or all taxes that pay for war and may be practiced by conscientious objectors , pacifists , or those protesting against a particular war. The earliest and most widespread forms of taxation were the corvée and tithe , both of which can be traced back to

2627-412: The 17th-highest per-capita (per-person) property tax revenue in the country at $ 1,559, up from 31st in 1996. In 2019, WalletHub applied California's statewide effective property tax rate of 0.77% to the state median home market value of $ 443,400; the annual property taxes of $ 3,414 on the median home value was the 9th-highest in the United States. Proposition 13 sets the assessed value of properties at

2698-492: The 2% cap only allowed a 67% increase in taxes on homes that were not sold during this 26-year period. A 1993 report from the joint University of California and State of California research program, California Policy Seminar (now the California Policy Research Center), said that a property tax system based on acquisition value links property tax liability to ability to pay and has a progressive impact on

2769-468: The 50% mark in control in order to avoid a reassessment. The Legislature could close this loophole with a 2/3 vote. In 2018, the California Board of Equalization estimated that closing this loophole would raise up to $ 269 million annually in new tax revenue. There have been several legislative attempts to close the loophole, none of which have been successful. Proponents of split roll have said

2840-517: The American junior college movement was launched in California when the state legislature authorized high schools to offer lower-division college-level coursework, thereby enabling more high school graduates to attempt such courses without having to move away for college. California was the proud leader of this movement, in that the United States went from zero junior colleges in 1900 to nineteen by 1915, of which eight were based in California. In 1960,

2911-643: The Roman poll tax during the 1st century CE , culminating in the First Jewish–Roman War . Other historic events that originated as tax revolts include Magna Carta , the American Revolution and the French Revolution . War tax resisters often highlight the relationship between income tax and war. In Britain income tax was introduced in 1799, to pay for weapons and equipment in preparation for

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2982-465: The Second District determined that the two-thirds (2/3) voter approval requirement for special taxes under Proposition 13 applied to citizens initiatives . There are several theories of the origins of Proposition 13. The evidence for or against these accounts varies. One explanation is that older Californians with fixed incomes had increasing difficulty paying property taxes, which were rising as

3053-409: The ability of community college districts to levy property taxes, Proposition 13 shifted the state's contribution to community colleges from 38% to 78% of their revenue. During the early 1960s, there were several scandals in California involving county assessors . These assessors were found rewarding friends and allies with artificially low assessments, with tax bills to match. These scandals led to

3124-437: The balance of the housing market because it provides disincentives for selling property, in favor of remaining at the current property and modifying or transferring to family members to avoid a new, higher property tax assessment. Proposition 13 reduces property tax revenue for municipalities in California. They are forced to rely more on state funding and therefore may lose autonomy and control. The amount of taxes available to

3195-420: The beginning of civilization . The corvée was state-imposed forced labour on peasants too poor to pay other forms of taxation ( labour in ancient Egyptian is a synonym for taxes). Low taxes helped the Roman aristocracy increase their wealth, which equalled or exceeded the revenues of the central government. An emperor sometimes replenished his treasury by confiscating the estates of the "super-rich", but in

3266-511: The current owner than to any potential buyer, so selling it often makes no economic sense. Owners of commercial real estate benefited under the original rules of Proposition 13: If a corporation owning commercial property (such as a shopping mall) was sold or merged, but the property stayed technically deeded to the corporation, ownership of the property could effectively have changed without triggering Proposition 13's reassessment provisions. These rules were subsequently changed; under current law,

3337-407: The election of Ronald Reagan . Another explanation that has been offered is that spending by California's government had increased dramatically during the years prior to 1978, and voters sought to limit further growth. The evidence supporting this explanation is limited, as there have been no studies relating Californians' views on the size and role of government to their views on Proposition 13. It

3408-454: The goal is to pay as little tax as possible rather than to keep as much post-tax income as possible. A resister may decide to reduce their tax paid through illegal tax evasion. For instance, one way to evade income tax is to only work for cash-in-hand , therefore circumventing withholding tax . Some tax resisters refuse to pay all or a portion of the taxes due but then make an equivalent donation to charity. In this way, they demonstrate that

3479-539: The high inflation of the 1970's. Most landlords did not do this, which became a motivating factor for rent control . Some businesses have exploited a property transfer loophole in Proposition 13 implementing statutes created by the California Legislature that define what constitutes a change in property ownership. To take advantage of this loophole, businesses only have to make sure that no partnership exceeds

3550-410: The highest brackets in the 1960s while local officials raised regressive state and local taxes, creating a "pocketbook squeeze" that made voters less likely to approve local levies and bonds, which eventually led to the passage of Proposition 13. The study said the tax revolt was not limited to white voters nor associated with rising conservatism associated with the collapse of the " New Deal order" and

3621-415: The host community. Others argue that the real reason for the claimed negative effects is lack of trust for elected officials to spend the public's money wisely. Business improvement districts are one means by which property owners have chosen to tax themselves for additional government services. Property owners find that these targeted levies are more palatable than general taxes. Proposition 13 alters

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3692-440: The housing supply and raising housing prices. Section 1. (a) The maximum amount of any ad valorem tax on real property shall not exceed one percent (1%) of the full cash value of such property. The one percent (1%) tax to be collected by the counties and apportioned according to law to the districts within the counties. Proposition 13 declared property taxes were to be assessed their 1976 value and restricted annual increases of

3763-422: The initiative presaged a " taxpayer revolt " throughout the country that is sometimes thought to have contributed to the election of Ronald Reagan to the presidency during 1980. Of 30 anti-tax ballot measures that year, 13 passed. The proposition has been called the " third rail " (meaning "untouchable subject") of California politics, and it has generally been unpopular for lawmakers to attempt to change it. As

3834-417: The intent of Proposition 13 was to protect residential property taxes from spiking and say the broad application of Proposition 13 to commercial property is a loophole while opponents say voters deliberately sought to extend Proposition 13 protections to commercial property by rejecting a split roll measure promoted by then-Governor Jerry Brown , Proposition 8, in 1978 (on the same ballot as Proposition 13), by

3905-437: The intent of their resistance is not selfish and that they want to use a portion of their earnings to contribute to the common good. For instance, Julia Butterfly Hill resisted about $ 150,000 in federal taxes, and donated that money to after school programs, arts and cultural programs, community gardens, programs for Native Americans, alternatives to incarceration, and environmental protection programs. She said: I actually take

3976-574: The later period, the resistance of the wealthy to paying taxes was one of the factors contributing to the collapse of the Empire. Because taxation is often oppressive, governments have always struggled with tax noncompliance and resistance. It has been suggested that tax resistance played a significant role in the collapse of several empires , including the Egyptian , Roman , Spanish , and Aztec . Reports of collective tax refusal include Zealots resisting

4047-504: The money that the IRS says goes to them and I give it to the places where our taxes should be going. And in my letter to the IRS I said: "I'm not refusing to pay my taxes. I'm actually paying them but I'm paying them where they belong because you refuse to do so." Some resisters refuse to willingly pay only certain taxes, either because those taxes are especially noxious to them, or because they present

4118-444: The most progressive in the United States, in part due to its high marginal income and capital gains rates. Since wealth is associated with ownership of "intangible" assets like stocks, bonds, or business equity, which are exempt from wealth taxes , ITEP says regressive state tax distributions that rely on property taxes on real property can worsen inequality, and that of all US states in 2018, California's tax code reduced inequality

4189-591: The most vocal and visible advocates of Proposition 13. Officially named the People's Initiative to Limit Property Taxation, and known popularly as the Jarvis-Gann Amendment, Proposition 13 was listed on the ballot through the California ballot initiative process, a provision of the California Constitution that allows a proposed law or constitutional amendment to be offered to voters if advocates collect

4260-472: The most. By comparing California over the period 1970 to 2000 with other states, (using data from the US Census Bureau , not state or county-level property records) Wasi and White (2005) estimated that Proposition 13 caused homeowners to increase the duration of time spent in a given home by 9% (1.04 years), and renters to increase their tenure by 18% (0.79 years). They also estimated that this effect

4331-518: The municipality in any given year largely depends on the number of property transfers taking place. Yet since existing property owners have an incentive to remain in their property and not sell, there are fewer property transfers under this type of property tax system. California also has high rates of migrants from other countries and states, which has contributed to more demand for housing, and it has low amounts of moderately priced housing. The different tax treatment can make real estate more valuable to

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4402-422: The numerous tax resistance methods, below are some of the legal and illegal techniques used by war tax resisters: A resister may lower their tax payments by using legal tax avoidance techniques. Some taxpayers pay their taxes, but include protest letters along with their tax forms. Others pay in a protesting form—for instance, by writing their cheque on a toilet seat or a mock-up of a missile. Others pay in

4473-444: The passage of Assembly Bill 80 (AB 80) in 1966, which imposed standards to hold assessments to market value. The return to market value in the wake of AB 80 could easily represent a mid-double-digit percentage increase in assessment for many homeowners. As a result, a large number of California homeowners experienced an immediate and drastic rise in valuation, simultaneous with rising tax rates on that assessed value, only to be told that

4544-491: The proportion of the early 1950s. One example of the massive expansion of government in California in the decades before Proposition 13 was the rapid growth of public postsecondary education. In 1900, California had only a single public university at Berkeley, the University of California , and state normal schools which provided two-year teacher training programs at Chico, Los Angeles, San Diego, and San Francisco. In 1907,

4615-525: The tax structure, based on income. It said that a revenue-neutral Los Angeles County reform which raises all assessments to true market value and lowers the property tax rate would harm elderly and low-income households. The think tank Institute on Taxation and Economic Policy (ITEP) considers property tax caps like Proposition 13 poorly targeted and instead advocates "circuit breaker" caps or homestead exemptions to levy property taxes based on ability to pay; yet in 2018, ITEP ranked California's tax code as

4686-420: The tax to an inflation factor, not to exceed 2% per year. A reassessment of the property tax can only be made a) when the property ownership changes or b) there is construction done. The state has been given the responsibility of distributing the property tax revenues to local agencies. In addition to decreasing property taxes and changing the role of the state, Proposition 13 also contained language requiring

4757-419: The taxed monies would be redistributed to distant communities. Cynicism about the favoritism of the tax system towards the wealthy and well-connected persisted into the 1970s. The ensuing anger started to form into a backlash against property taxes which coalesced around Howard Jarvis , a former newspaperman and appliance manufacturer, turned taxpayer activist in retirement. Howard Jarvis and Paul Gann were

4828-449: The third highest tax burden as a proportion of state income (tax-per-capita divided by income-per-capita) of 12.4% ($ 3,300 tax per capita, inflation adjusted). By 2012, it had fallen slightly to the sixth highest rate, 10.9%, ($ 4,100 tax per capita, inflation adjusted). California has the highest marginal income and capital gains tax rate and is in the top ten highest corporate tax and sales tax rates nationally. In 2016, California had

4899-538: The time of purchase (known as an acquisition value system), with a possible 2% annual assessment increase. As a result, properties of equal value can have a great amount of variation in their assessed value, even if they are next to each other. The disparity grows when property prices appreciate by more than 2% a year. The Case–Shiller housing index shows prices in Los Angeles, San Diego, and San Francisco appreciated 170% from 1987 (the start of available data) to 2012 while

4970-494: Was more pronounced in the coastal cities, with the increase in tenancy by owner-occupiers in the Bay Area being predicted at 28% (3.0 years), Los Angeles 21% (2.3 years), and Fresno 7% (0.77 years). They speculate that renters may have longer tenure due to less turnover of owner-occupied housing to move into. Other studies have found that increased tenure in renting can be attributed in part to rent control . A 2016 report from

5041-610: Was passed, property tax revenue to local governments declined by roughly 60% statewide. However, by 2003, the inflation adjusted property tax collected by local governments exceeded the pre-1978 levels, and has continued to increase. In 2009, the advocacy group Howard Jarvis Taxpayers Association estimated that Proposition 13 had reduced taxes paid by California taxpayers by an aggregate $ 528 billion. Other estimates show that Proposition 13 may not have reduced California's overall per-capita tax burden or State spending. The think tank Tax Foundation reported that in 1978, Californians had

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