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This statutory language “indicates that when a case is transferred from the district court to the tax court, the tax court acquires the district court’s jurisdiction to decide all issues in a particular case, implicitly including all constitutional issues.” d 910, 920 (Minn. 1980).

axpayer challenges a county’s valuation of real property by filing a petition in the tax court, see Minn. Stat. § 278.01 (2024), there is a prima facie presumption that the assessor’s valuation was proper, and “the burden is on the party appealing that assessment to show that it is excessive.” (); see also Minn. Stat. § 271.06, subd.

(“The language designating the tax court as the ‘sole, exclusive, and final authority’ for all issues raised in a particular case suggests that the legislature intended the tax court to have the power to decide each case completely.”).

It cites to our decision in d 910, 920 (Minn. 1980), in which we held that the tax court may decide constitutional claims in some instances.

“A facial equal- protection challenge alleges that the statute creates at least two classes of individuals, which are treated differently under the statute, and that this difference in treatment cannot be justified.” ().

External, or economic, 15 obsolescence “is the measurement of a property’s loss in value as a result of factors beyond the physical boundaries of the property and beyond the owner’s control.” Guardian Energy, d at 262-63; n.10 (Minn. 1980) (defining economic obsolescence as an “impairment of desirability or useful life arising from factors external to the property”).

Soc’y of the U.S., d at 553, a tax court can “rely exclusively on the cost approach when valuing special purpose property” such as an ethanol plant.8 SMBSC, d at 556; (“The very nature of special purpose property is such that market value cannot readily be determined by the existence of an actual market, and therefore other methods of valuation, such as reproduction cost, must be resorted to.”).

“By definition, a facial challenge to a statute on equal protection grounds asserts that at least two classes are created by the statute, that the classes are treated differently under the statute, and that the difference in treatment cannot be justified.”

Gonzales v. Comm’r of Revenue

d at 657 (“In the narrow context of special purpose properties, we have generally permitted the use of a cost approach alone because, ‘[t]he very nature of special purpose property is such that market value cannot readily be determined by the existence of an actual market, and therefore other methods of valuation, such as reproduction cost, must be resorted to.’ ” ()).

“By definition, a facial challenge to a statute on equal-protection grounds asserts that at least two classes are created by the statute, that the classes are treated differently under the statute, and that the difference in treatment cannot be justified.”

1 (2000); (recognizing the tax court as “essentially an administrative agency, deriving its power from a grant by the legislature”).

1 (2000), as well as our decisions in and Northwest Airlines, that the Main Base Building is not income-producing property because the legislature intended that relator’s leasehold interest, not MAC’s fee interest, should be the taxable subject property-therefore we must disregard the 19

1 (1998); (recognizing the tax court as “essentially an administrative agency, deriving its power from a grant by the legislature”).

In order to prevail on a facial challenge to a statute on equal protection grounds, a taxpayer must prove, beyond a reasonable doubt, “that at least two classes are created by the statute, that the classes are treated differently under the statute, and that the difference in treatment cannot be justified.”

“[Ljegislative classifications not based on a suspect class nor affecting fundamental interests, as these have been defined by the United States Supreme Court, must be upheld under the equal protection and uniformity clauses unless there is no reasonable basis for the classification.”