review and the local assessor from applying the exemption during the proceedings the fan in l u v s shooting was allowed to intervene it's a big space operator at the rock island exemption but if you this is it to a for profit business then then it's entered on the rolls and it's taxed as if it's the fionn meaning lessees taxes feel and it's done be it since it's a process that's unique to that kind of less there is a number of cases out that were all might only apply to those particular pieces of property so it's it it's special nature arm doesn't have all the class numbers were similarly situated the question is is there anybody else similarly situated with special legislation challenges and in the peoria school district case which is the most recent case on this issue up the court look at that and there was a case where they cha nged the laws about which are which bore would hear police security employment issues and and there was only one was the school district in the state who had a police security force at the time now and the same for as well as his a business plan and it would be across the river and you know if it saves this money it's going to have jobs but that doesn't mean that there couldn't be an f b o there's nineteen of the airports with put those debates because it was it was kind of interesting to us when we looked at that and basically he said the powers that be said no no the lancing which are generals that well it's you know it's all about power up above or something ah he said the beyond my pay grade as well but it's one of those things where obviously lansing was originally people in lansing but they should be included and in the point his sister with can beat up yours of the future who will be competing with somebody in another state but they won't be able to be keep jobs in illinois but other it b o s should have been able to have the same we can argue other employers the concept here is if i lower your taxes you're going to be in a position to use those mon it comes into play and prevents the steady because it's too narrow and basically if you read the peoria case they said this only applies in this one's police force of this one school at this point in time there's only one in the class but  and other these other nineteen other airports who are competing across state lines that would would likely have exemptions at their airport and would like to be able to have a job you know and have the jobs there which would take advantage of the same law it was available to those  very same circumstance in the near future and not be able to take care take advantage of this and in what i was pointing to was the other f b o is that might take root at this airport why not even wanna increase jobs i mean it could be they would just set up shop and keep the money for themselves there's nothing that makes them to get so the earliest you need then swap interesting and certainly a lot of of businesses you want to import a policy issue for the state isn't so unique that it's border and wouldn't get more of the general lobby better that you can get an exemption to get jobs and he would be able to meet the same public purpose the rational basis as runs to the idea that the attributes of real estate are considered our real estate and sole leaseholds are real estate in because the constitution says exemptions from real estate are limited to only certain types of persons and certain uses clear that the legislature here in large the enumerated persons in uses it must be constricted to those set forth in the constitution which are charitable and government uses in an agricultural uses and in some other this the constitutional limitations on giving exemptions to the lessees of government property the lessees a government property had real estate a piece of the real estate they have this this lessees interest in the real estate and under the constitution that interest in real estate is subject to tax and it's not allowed to get an exemption and that's what argument is with regard to that section i can go into longer details but one morning on the time my l it was uniformity of taxation and then kind of goes hand in hand with the idea that because intuition says that exemption is limited limit limited to our role as persons in uses that are that are this law to get exemption which is a zero assessment we're all more or less these and all of the feel owners are subject to the other rules this law is making you know a blatant lack of uniform in our brief from his brief let's begin with the burden of proof here and explain and then explain the straightforward or constitutional standard for exemption under article one section six we're not talking anything statutory that's an important distinction and i thought i'd just heard counsel concede that most of the cases that he's discussed in his brief have emphasized statutory consideration yes but not constitutional ones and as we are standard of review which places for the burden of proof which places a heavy responsibility on the party challenging the constitutionality of the statute so even if the school district here raises a question or based on who owned the car wash and second the party leasing property must be principly can gauge in activities that ordinarily that occur relate to what ordinarily occurs on property so the functions that ordinarily occur on their property and that's that was the critical focus of the hundreds and pontiac case by the supreme court the question of focus was on what is going on the b o services are intergroup and essential furthering the airports public function so the second set factor is satisfied the first back to you satisfied as well on ownership it's not it's not whether an f b o was mentioned in the constitution it's whether a unit of local government is and it is and their position as i understand is that the constitution forbids leatham and the constitution nor says that i don't want to run it's my own it's time rumors of short the school or supreme court has told us that the purpose is to prevent the legislature from arbitrarily discriminating in favor of one person or group and the scrutiny of others who are similarly situated you can write in there is there is that possible but what the news was there was no evidence that anyone was considering at the trial court level or in the record and what the evidence was and the judge noting found was that in fact this  the special legislation was never implicated because they have not proven that there was any similar situated hours but even if the special legislation clause is implicated your next step then is to conduct a rational basis analysis after i think the legislative history was clear this was passed overwhelmingly by a by bipartisan group of legislators and the discussion was this is for economic growth economic benefit  only it yes it does but it's designed when you read the legislative history to incentivize going to stay here to stay in illinois instead of going to iowa to bring the jobs and the money until i don't it's also important to think along those lines you're going to note that it's actually nearly tailored which is a good thing because the residents of the county of rockhampton are the ones that are going to benefit from the expansion at the same time rock island is losing our air and the taxing bodies are losing out on some revenue but which a good thing is you know in other counties whether it's winnebago up in rockford whether it's crook whether it's whatever might do it's an interesting story but other appeals might expand and create jobs in illinois and if they get a tax break might feed it too just because they say they might do it doesn't mean they're going to do it and more importantly case the court was very clear there was no evidence another school district was going to do a police force but the court said if this is a good idea that hell is this change and in the in the board for police forces schools then other would be a difference in the taxes but it would really depend on what what that expansion is if it's if it's real estate or if it's just business of a business line obs so with regard to  uses we're not talking about affect the feet we're not asking the authority to be taxed we're looking at the property interest of the lessees here and we're saying that the lessee can't get the exemption because the constitution blocks and is therefore probably here so that