Associated Industries of Missouri v. State Tax Commission of Missouri

BLACKMAR, Judge.

Individual and corporate taxpayers filed a declaratory judgment action, challenging the constitutionality of § 137.016, RSMo Supp.1984 classifying as residential “all real property improved by a structure .., which contains not more than four dwelling units.... ” By reason of this classification, the involved property is assessed at 19% of its fair market value, whereas other rental property is classified in the general classification and assessed at 32% of its value. The trial court held that the statute violated the due process and equal protection clauses of the Fourteenth…