In Downingtown Area Sch. Distr. v. Chester County Bd. of Assessment Appeals, 590 Pa. 459, 913 A.2d 194 (2006), a shopping center was sold for approximately $ 10 million. At the time of sale, the property was assessed at $ 5.8 million. Consequently, the school district appealed the assessment and a hearing before common pleas eventually followed, at which time the school district sought to increase the property's assessment to $ 8.5 million. At the hearing, the parties stipulated that the property had a fair market value of $ 8.5 million, that the EPR was 100%, and that the CLR was 85.2%. The taxpayer's expert then testified that seven other similar shopping centers in the county were assessed at rates between thirty-six and sixty-three percent of current market value, lower than the subject property. Common pleas concluded that since shopping centers did not constitute a separate class for uniformity purposes and the STEB-calculated CLR superseded prior methods of determining uniformity, the taxpayer's evidence of assessment rates of similar properties was irrelevant. Common pleas granted the school district relief and applied the EPR of 100% to the stipulated market value of $ 8.5 million. The Court affirmed. On appeal, our Supreme Court reviewed historic decisional law, including Brooks, Deitch and Keebler, to identify both the principles underlying the constitutional requirement of tax uniformity and the burdens of proof and evidence required in a uniformity challenge. In addition, the Court examined the current statutory scheme, taking note of its inherent inequities and the existing potential for discrimination. The Court observed that although the Uniformity Clause has been interpreted to preclude real property from being divided into separate classes for purposes of systemic tax assessment, that general principle did not eliminate the need to "consider meaningful sub-classifications as a component of the overall evaluation of uniform treatment in the application of the taxation scheme." Id. at 469, 913 A.2d at 200. A complete disregard of meaningful sub-classifications, clearly evidence which would be deemed to be relevant under the Deitch construct, would represent "an impermissible departure from federal equal protection jurisprudence, which not only represents the floor for Pennsylvania's uniformity assessment but clearly contemplates the seasonable attainment of rough equality in treatment among similarly situated property owners." Id. at 469, 913 A.2d at 200-01. Thus, the Court opined: "While the Commonwealth may certainly seek to achieve overall uniformity by attempting to standardize treatment among differently situated property owners, its efforts in this regard do not shield it from the prevailing requirement that similarly situated taxpayers should not be deliberately treated differently by taxing authorities." Id. at 470, 913 A.2d at 201.