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OCR: personal property and real property together, State could cxempt all business personal property from tax yet not be found violate subsection (b)(4) Sec RPI Br. 5 many States, including Oregon, the sunout of business real property substantially larger than the amount of tangible business personal property See 1992) Manvel. 609 Property 611 (real Tax property Update Tax constitutes Notes 62 Feb percent total business tangible asscts) In those States. cluding both real and personal property in the comparison would mask the discrimination against rail property that results from the substantial exemptions other business persoual Under the proper standard, Oregon's tax violates sub- section {b}{4} The facts are stipulated. The total anount of taxed business personal property $48 bil- lion. Stipu ...