The opinion
Pfeifer, J.,
dissenting.
{¶ 59} Section 2, Article XII of the Ohio Constitution states that “[l]and and improvements thereon shall be taxed by uniform rule according to value * * The tax in this case is not uniform, because a 10 percent rollback provision applies to apartment buildings with three or fewer units but does not apply to apartment buildings with four or more units. See State ex rel. Park Invest. Co. v. Bd. of Tax Appeals (1964), 175 Ohio St. 410 , 412, 25 O.O.2d 432 , 195 N.E.2d 908 (“It is clear that under the Ohio law all real property, regardless of its nature or use, may be assessed and taxed only by a uniform rule on the basis of value”). I would reverse the decision of the Board of Tax Appeals. I dissent.