operations that are designed to benefit all citizens. An ad valorem tax is based upon the legal principles of equity and uniformity. That is, everyone must be treated fairly and equally. In special assessments, proportionality is a key element. A special assessment is premised upon the necessity for the public improvement and the fiscal burden imposed must be reasonably proportional to the benefit created. Unlike ad valorem taxes, special assessments are not expected to be uniformly levied (the same millage rate for each parcel). The fiscal burden is spread among only those properties within the special assessment district and it is apportioned to each property based upon the unique, specific and direct benefit the property received from the public improvement. Thus, a vacant lot might be assessed the same fee as an adjacent lot which has a million dollar home on it. For example, both the vacant lot and the property improved with a million dollar home, might be assessed Five Thousand Dollars ($5,000.00) for a sewer connection. So, while both properties have identical $5,000 special assessment obligations because sewer installations have been specially assessed, there will be a huge difference in their ad valorem tax levies; one ad valorem levy will be based upon the value of a vacant lot and the other will be based upon the value of the lot plus the million dollar home. Difficulty Among the unique characteristics of the special assessment is one that makes a special assessment particularly onerous for ordinary citizens. A special assessment levy enjoys a legal benefit known as a "presumption of validity." This means that it is much harder and usually, much more expensive to appeal than the ad valorem property tax most citizens are familiar with. This happens because it is difficult for the ordinary citizen to recognize that an error in the special assessment procedure or methodology has occurred and the resources a taxpayer must use to fight a special assessment levy are more expansive and costly than resources to fight an improper ad valorem tax on their real estate. For example, most property taxpayers intuitively understand market forces associated with the value of their homes or other property. Consequently, if the tax assessment seems out of line, they usually can recognize it quickly. In the case of special assessments, it is difficult for even professionals to grasp the complex nuances associated with the concepts of necessity