State Highway Comm'n v. Southern Dev. Case law on discrimination establishes the standards set out above. There is no case law which has approved the methodology, for valuation or discrimination, proposed by Complainants. Absent a showing of court approval of Complainants' methodology, the theory of discrimination and valuation is not founded upon proper elements or a proper foundation. Therefore, the tax consultant's theory of discrimination is without probative value.
Complainants contend the basis for their appeal is equity.
Equity in assessment is a very simple two step process. It is achieved when properties are valued at their true value in money or market value and then assessed at the ratio established by statute for a given class of property. Hotels do not constitute a separate class of property. Hotels are part of commercial property for assessment purposes. Commercial property, in general, in St. Charles county is assessed at thirty two percent of fair market value.