Whether the Equal Protection Clause mandates that a real estate taxpayer seeking a refund based on an over assessment of real property be able to challenge the methodology that the assessing official used and to conduct discovery on such assessment methodology, where that methodology is not probative to the refund claim that State law provides and where State law provides a complete and adequate remedy in which all objections to taxes may be raised

QUESTIONS PRESENTED 1. Whether the Equal Protection Clause mandates that a real estate taxpayer seeking a refund based on an over assessment of real property be able to challenge the methodology that the assessing official used and to conduct discovery on such assessment methodology, where that methodology is not probative to the refund claim that State law provides and where State law provides a complete and adequate remedy in which all objections to taxes may be raised. 2. Whether the decision below improperly held that the Tax Injunction Act and the comity doctrine did not bar federal jurisdiction over Respondents’ equal protection and due process challenges to Illinois’ system for seeking real estate tax refunds based upon error in the assessment of real estate, where: (1) Illinois law provides an action based upon equal protection principles to recover overpaid real estate taxes and interest and (2) under Illinois law, the assessment of real property at or above its true fair market value warrants a refund based upon the Uniformity Clause in the Illinois Constitution, where assessing officials have systematically under-assessed other, similar properties in its class.