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reported on tnree opinions regarding AF Districts handed down by the Attorney General. All involve taxation.

Before going into the Attorney General’s opinions, Purcell s»id it was first necessary to understand that use value taxation and AF Districts are exceptions to the general rules of the Virginia Constitution.

He noted that the constitution states that “all taxes...shall be uniform upon the same class of subjects.” Traditionally, property has been divided into two classes: public land and private land. Establishment of use value taxation, Purcell explained, added four additional classes: horticultural, agricultural, forestal and open space. He added that recognition of the four types of property as separate classes has yet to be tested in court.

Under state law, a locality may allow deferred taxes on horticultural, agricultural, forestal and open space land if it determines that such action is in the public interest and if the locality sets limits and standards for considering property for in(Continued

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