Does section 4986 of the California Tax Code require an application under Section 4986 to be filed?

⁴ The statutory scheme does not make any express provision for the filing of an application under section 4986, but decisions dating back to the 1930s hold that, at least in the case of a party claiming to be tax exempt, section 4986 is not self-executing and the tax-exempt party must apply before a tax can be cancelled. (City of Pasadena v. Chamberlain (1934) 1 Cal.App.2d 125, 133134, 36 P.2d 387 [construing the predecessor section to section 4986 ; holding that the provision allowing for the cancellation of a tax when the property is sold to a tax-exempt party after the tax lien date is not self-executing].) Also, section 4986 has, since 1941, required "satisfactory proof" ( 4986, subd. (a) ), which implies a contested proceeding initiated by an interested party. Finally, section 4986 has, since 2004, referred to the "initiat[ion]" of a "cancellation action" ( 4986, subd. (c) ), again implying a contested proceeding. Thus, it is clear that a taxpayer must invoke section 4986 by applying for cancellation.