upon its California sales, Macy's requested the Supreme Court to withdraw its case from consideration ( Fisher 1991b). A companion case, which concerned a homeowner's claim of unequal treatment with respect to other taxpayers, remained under Supreme Court review ( Nordlinger v. Lynch 1990). However, the question as to whether Proposition 13 gave rise to unconstitutional discrimination against interstate commerce was no longer before the Supreme Court ( R. H. Macy & Co. Inc. v. Contra Costa County 1991).
This survey of the special problems of business property valuation and taxation indicates both the difficulty and the importance of resolving these issues. The valuation of business property is particularly difficult because extensive and specially designed structures with a specific commercial or industrial use are less apt to be the subject of frequent market transactions and less likely to be readily comparable to other property. At the same time, the importance of business property to the local tax base, particularly in an era of diminishing support for local government at the state and federal levels, infuses disputes over these matters with political and fiscal importance beyond that generally found in property tax cases. To the extent the issues discussed here raise questions as to the fundamental nature of the property tax, they would deserve careful analysis in any event. The current crisis in local government finance may therefore serve to focus attention upon basic issues concerning the operation and interpretation of a major and longstanding tax.