Rothschild v. State Tax Com'n of Missouri

RENDLEN, Judge.

Respondents sought declaratory judgment to determine whether a 1986 State Tax Commission Advisory Order instructing county assessors to consolidate commonly owned dwelling units on contiguous properties in classifying real property as “commercial” or “residential” for purposes of tax assessment is a valid construction of § 137.016.1(1), RSMo 1986. 1 The circuit court held that § 137.016.1(1) “shall be interpreted so that ‘a structure ... which contains not more than four dwelling units’, regardless of the ownership or location of the property, is ‘residential’ property.” The…