The Strongs timely appealed to the State Tax Commission from the decision of the St. Charles County Board of Equalization. The property is a 3.56 acre tract improved with four paved streets and 53 concrete pads and patios. No new construction or property improvements occurred during 1997 which would require a change in value for 1998. The park is designed to accommodate recreational vehicles which are 8.6 feet wide and up to 50 feet long. These recreational vehicles range in size from 136 square feet to 430 square feet.
Tenants range from folding trailers to self-contained motor homes.
The length of time each vehicle spends in the park depends on the season and the use designated for the sites. From December through April, five sites are dedicated to short term guests and 48 sites are dedicated to long term guests. The majority of the park's tenants use their recreational vehicles as their full time residence and stay in the park more than one month. The proper classification of the subject property is subclass 3 commercial real property. Zimmerman has filed a petition for an injunction prohibiting Cactus Mobile Home Park from violating zoning regulations by renting space to recreational vehicle users.