In Stocker Resources, Inc. v. Assessment Appeals Bd. (1996) 49 Cal.App.4th 391, the hearing was not held within two years of the application, but the court held the taxpayer was estopped from raising section 1604, subdivision (c), because of the taxpayer's attorney's intentionally misleading conduct. The attorney had altered a waiver form which the board used for unconditional time waivers by limiting the date to which the waiver extended. The attorney did not alert the board to the modification of the form and, when the board set a hearing date six days later than the date specified on the altered waiver form, the attorney did not notify the board of the problem. The court found the attorney knew the board would not have agreed to a limited time waiver: "The evidence of deception is so strong we must infer that the attorney was manipulating events so that the board would be forced to adopt his client's opinion of market value under section 1604, subdivision (c)." (Id. at p. 399.) Stocker held that the taxpayer could not rely on section 1604, subdivision (c), when fraudulent conduct attributable to the taxpayer resulted in the board's failure to timely deal with the application. It did not establish a general principle that section 1604, subdivision (c), need not be applied when the result appears unjust to the county.