BILLINGS, Justice.
The appellees own real estate in the Town of Windsor consisting of a small shopping center on three acres of land. On April 1, 1976, the town listers set the value of this property for tax purposes at $415,000. The taxpayers appealed to the Board of Civil Authority, which reduced this valuation to $400,000. The taxpayers then appealed to the Windsor County Superior Court, which ordered the town to list the property at $280,000.
The appellant...
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