State Ex Rel. Frizzell v. Dwyer

I cannot agree with the reasoning or the result reached in the foregoing opinion.

Equality and uniformity in taxation refer to an equality in the burden of taxation, so that no higher rate or greater levy in proportion to value is imposed on one species of property than on others similarly situated or of like character. Equality in taxation is accomplished when the burden of the tax falls equally and impartially on all the persons and property subject to it, so that no higher rate or greater levy in proportion to value is imposed upon a class of property. (84 C. J. S., Taxation, § 22 [b].)…