Bugs, I agree, but isn’t it the assessor’s burden to show that the purchase price is not the full cash value? I rely on section 110 of the California Revenue and Taxation code:
“(b) For purposes of determining the “full cash value” or “fair market value” of real property… being appraised upon a purchase, “full cash value” or “fair market value” is the purchase price paid in the transaction unless it is established by a preponderance of the evidence that the real property would not have transferred for that purchase price in an open market transaction. The purchase price shall, however, be rebuttably presumed to be the “full cash value” or “fair market value” if the terms of the transaction were negotiated at arms length between a knowledgeable transferor and transferee neither of which could take advantage of the exigencies of the other…“