Whether a real property tax class that consists of certain residential properties that are distinguished from identical residential properties based solely on whether the properties have an assessed value of $1,000,000 or more, which results in different tax rates being charged on the first $999,999.99 of a property's value, so that the owner of a property valued at $1,000,000 or more pays a higher tax rate on the first $999,999.99 of value than the owner of a property valued at $999,999.99 or less, amounts to unequal treatment rendering the tax classification unconstitutional under the Equal Protection Clause of the Fourteenth Amendment.

Whether a real property tax classification that distinguishes residential properties based on a $1,000,000 valuation threshold amounts to unequal treatment violating the Equal Protection Clause