In Steinhart v. County of Los Angeles (2010) 47 Cal.4th 1298, the issue before the court was whether real property was subject to reassessment under Proposition 13. There, the plaintiff was the sister of a trust settlor who died and left the plaintiff a life estate in the settlor's residence. The trust settlor had transferred this residence to a trust that was revocable during the settlor's life but that became irrevocable upon the settlor's death. The county auditor took the position that the settlor's death resulted in a change in ownership that triggered reassessment. The plaintiff filed a claim for refund of the additional property taxes she had paid without first seeking an assessment reduction under section 1603. The Steinhart court held the plaintiff was required to apply for an assessment reduction and therefore her refund claim was barred for failure to exhaust administrative remedies. (Steinhart, supra, 47 Cal.4th at p. 1313.) The court noted that the plaintiff and the county each interpreted the "nullity" precedents very differently. The plaintiff argued that exhaustion was unnecessary because there was no question of valuation that the assessment appeals board had special competence to decide and there was no dispute as to the relevant facts. In contrast, the county, citing Stenocord, argued the assessment was not a nullity because the property was not "tax exempt, nonexistent, or outside the jurisdiction." (Steinhart, supra, 47 Cal.4th at p. 1311.) However, the court did not need to choose between these divergent interpretations of its precedents. Rather, "the Legislature has expressly and definitively settled the exhaustion question insofar as it involves a challenge to a change in ownership determination." (Ibid.) Section 1605.5, enacted in 1986, provides that the "county board shall hear applications for a reduction in an assessment in cases in which the issue is whether or not property has been subject to a change in ownership ... ." ( 1605.5, subd. (a).) The Steinhart court also concluded that section 5142, subdivision (b), added in 1993, further confirms that an assessment reduction application under section 1603 is a prerequisite to challenging a change in ownership determination. (Steinhart, supra, 47 Cal.4th at p. 1312.) Subdivision (b) of section 5142 specifies that, in the context of a claim for refund, if the taxpayer and the assessor file a stipulation with the county board of equalization "stating that issues in dispute do not involve valuation questions" and the stipulation is accepted, it shall be deemed compliance with section 1603. Section 5142, subdivision (c), provides that nothing in subdivision (b) "shall be construed to deprive the county board of equalization of jurisdiction over nonvaluation issues in the absence of a contrary stipulation." Thus, the absence of a valuation issue does not necessarily eliminate the need for the taxpayer to apply for an assessment reduction before pursuing a tax refund claim. In short, a trust settlor transferred her residence to a revocable living trust. She was the sole present beneficiary of the revocable trust, and the trust document provided that upon her death, the trust became irrevocable and her sister had the right to occupy the residence during her lifetime with the remainder to their siblings and issue. (Steinhart, supra, 47 Cal.4th at p. 1303.) The court concluded a change of ownership occurred upon the settlor's death because her equitable and beneficial interest in the real property passed to the sister and the siblings. The Supreme Court in Steinhart concluded trust beneficiaries hold " 'an equitable estate or beneficial interest in' property held in trust and are ' "regarded as the real owners of that property." ' " (Steinhart, supra, 47 Cal.4th at p. 1319.)