To meet ever-increasing demands for public services, local governments have relied upon taxation of real property as a primary source of revenue.' Since most realty is subject to these exactments, the number of individuals affected is substantial. The statutory framework for realty taxation has been complicated by the emergence of the condominium form of property ownership. Usually, a condominium owner holds title to his particular apartment or unit in fee simple. In addition, he has an undivided interest in "the land and all other parts of the building held for the common use or benefit of the unit owners." Although the form which the condominium assumes may be residential or commercial, freehold or leasehold, the individual holders possess real property interests subject to taxation.
The condominium presents taxing authorities with a two-phase assessment problem. The value of the overall property must first be appraised, a task made difficult by the scarcity of relevant market data. Once the assessed value is determined, the tax liability must be equitably apportioned among the unit holders. Should the authorities fail to make fair assessments, the unit holders must, in turn, choose the most effective means of mounting a tax protest.