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I <br /> I <br />,I <br /> I <br /> I <br /> I <br /> ! <br /> <br />,I <br /> I <br /> <br />I <br />I <br />I <br /> <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />abandoned in 1979, much property in the State was taxed below its <br />full market value. <br /> <br /> The plaintiffs in McCannel were property owners whose <br />property did not qualify for limited market value assessment. They <br />argued that because their property was taxed at full value while <br />others' was not, they were being deprived of equal protection of the <br />laws. <br /> <br /> The Supreme Court analyzed the case in traditional equal <br />protection terms. It identified two classes of property created by <br />the statute -- property subject to the limited market value <br />assessment and property that was not. Acknowledging the broad <br />latitude granted to the legislature in establishing classifications, <br />particularly in the tax field, the Court held that the challenged <br />statute would have to be upheld against equal protection challenge <br />if any rational basis for the classifications could be found. <br /> <br /> The defendants argued that the purpose for the limited <br />market value statute was to gradually absorb significant increases <br />in property value caused by rapid 'inflation, in order to avoid the <br />imposition of sudden, drastic property tax increases. The Court <br />held that this reason was sufficient to justify the differential <br />treatment attacked by the plaintiffs. Moreover, the Court rejected <br />additional contentions that are likely to be echoed in the instant <br />lawsuit: <br /> <br />-29- <br /> <br /> <br />