Many of New York’s most important property tax cases over the past quarter century have come from Long Island, especially Nassau County. Following this tradition, two of the more interesting property tax cases over the last year or so involve Nassau County.

The most recent such case upholds the County’s classified assessment system, which results in vast inequities. It also illustrates the point that in matters of taxation, it is almost impossible to prove violations of the constitutional rights of equal protection. Tilles Investment Co. v. Gulotta[1] was the Appellate Division’s reversal of a Supreme Court decision holding that the classification system in Article 18 of the Real Property Tax Law, as applied in Nassau County, properly raised an equal protection argument as to the uniformity of assessments.