LOWENSTEIN, Judge.
This appeal involves two suits arising out of a Missouri Tax Commission construction of § 137.016.1(1), RSMo 1986. Subpart (1) creates a sub class for taxation purposes of "residential property," which, as relevant here, contains a structure for dwelling purposes which contains not more than four dwelling units. Section 137.115 allows an assessment rate of 19% of value on "residential" property or alternatively at 32% if the property is classified...
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