SMITH, J., delivered the opinion of the Court.
Apparently piqued at what it regarded as inadequate real property assessments, Montgomery County enacted a tax statute intended, as put in its brief, to be applicable to a seller who "is revealed to have derived real income from his property in that he enjoyed the use of the property at a lesser tax burden than the sale reveals he should have borne" and to thus impose "an excise on that income, taken, not retroactively...
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