San Diego Law Review

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In Allegheny Pittsburgh Coal Co. v. County Comm'n the United States Supreme Court held that it was an unconstitutional violation of equal protection for the assessor of Webster County to subject similarly situated properties to different tax burdens depending on when they were purchased. The Court stated it "need not" and did not decide whether the California Constitution, enacted as Proposition 13, would "stand on a different footing." The Court's collateral reference has inspired recent challenges to Proposition 13. This Note addresses the United States Supreme Court's equal protection analysis and its possible application to California's Article XIII A.

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