In June, I wrote about the California Supreme Court's disappointing decision in 926 N. Ardmore Ave. v. County of L.A., 2017 Cal. LEXIS 4768 (Cal. 2017). See California Supreme Court Affirms Novel M&A Tax. Readers may recall that the Supreme Court applied the concept of a change in ownership for purposes of triggering property tax reassessments under Proposition 13 to California's documentary transfer tax. While this has some very superficial appeal, it is an unnatural yoking of two very different laws. When the taxpayer requested a rehearing, I and several others submitted amicus letters in support. Obtaining a rehearing is very much a long shot, but as they say, "you miss every shot that you don't take". Regrettably, the Supreme Court had no appetite to revisit the issues. Perhaps the next challenge will be in the federal courts.