dissenting.
The theory developed by the majority to solve this interesting issue is unsupported by the text and structure of the underlying statute. By defining “value” as “market value,” the majority defines away the very issue this case presents for resolution. But the statute is not that simple. If the legislature had wanted to achieve the result the majority reaches here, it could simply have enacted a statute requiring shopping center property to be valued at fair market value using whichever of the three generally accepted methods best achieves it. But A.R.S. § 42-147 sets up an elaborate mechanism by which shopping center property is valued.
Section 42-147(A) requires the county assessor to use the replacement cost less depreciation method to value shopping center property, unless the taxpayer elects the income method. Thus, in all cases in which the taxpayer chooses not to elect the income method, all shopping center property in Arizona will be evaluated by the replacement cost less depreciation method. And this is true whether that method produces fair market value or not. As long as there is no appeal, and no election by the taxpayer to use the income method, the mechanism stops at the replacement cost less depreciation method. The majority’s theory fails to account for this. It claims that fair market value is the sine qua non of the valuation of shopping center property, but under its theo*563ry, a reviewing body can only look at fair market value in the event there is an appeal under the income method.
Now, if the taxpayer elects the income method under the authority of § 42-147(C), the assessor may use that method ab initio. But whether the taxpayer makes that election at that level or not, upon a review or appeal under § 42-147(B), the taxpayer may elect the income method known as the straight line building residual method subject only to the provision of subsection D.
Subsection D provides that upon appeal of a valuation determined by the income method (under subsection C), or an appeal where the taxpayer has elected the income method (under subsection B), “if after computing the value by the income method the reviewing body finds that other valuation factors must be applied to determine the value of the property it may utilize such other factors as it finds necessary____” A.R.S. § 42-147(D) (emphasis added). Under the majority’s theory, “other valuation factors” means that all bets are off. The reviewing body would not be bound by either the income method or the replacement cost less depreciation method, the only two valuation methods prescribed by the statute. See subsection E(2)(B) (“the two valuation methods”). Under the majority’s theory, then, in those rare instances in which the taxpayer chooses the income method and there is an appeal, the only two methods prescribed by § 42-147 may be ignored and the reviewing body is free to determine fair market value in ways it sees fit. But why would the legislature authorize the reviewing body to do this only in that rare class of cases? After all, if the taxpayer does not elect the income method, or if there is no appeal, everyone is stuck with the replacement cost less depreciation method required by subsection A, whether that method produces fair market value or not. I thus believe that the majority’s theory is simply unsupported by the structure of the statute.
What then does the reference to “other valuation factors” in subsection D mean? It cannot mean another method because the statute uses the word “method” in subsection A with respect to the replacement cost less depreciation method, in subsection B with the “income method,” known as the “straight line building residual method,” and the word “method” is used three separate times in subsection D in connection with the “income method.” Thus, if the legislature were referring to another “method” it would have simply said so. We first discuss “method” and then “factors.”
The generally accepted methods of valuing a shopping center are the “cost replacement method” and the “income approach method.” Grossman v. Westmoreland II Investors, 123 Ariz. 223, 224, 599 P.2d 179, 180 (1979). The comparable sales method is inapplicable to shopping centers. Encyclopedia of Real Estate Appraising 402, 411 (Edith J. Friedman ed., 1968) [hereinafter Friedman 1968]; Encyclopedia of Real Estate Appraising 437, 444 (Edith J. Friedman gen. ed., 3d ed., 1978) (“In neighborhood centers, as in regional centers, the Income Approach is the final determinant of value, and the Market Comparison Approach is of limited use.”) [hereinafter Friedman 1978]. The 1978 Friedman treatise preceded the enactment of our statute by just four years. And this court, three years before the statute was enacted, acknowledged the inapplicability of the comparable sales method to shopping center property. In determining cash or market value, the court discussed the three methods of assessment.
First is the cost replacement method, that is, the initial value or cost of the property plus appreciation and less depreciation. Second is the market data method, that is, the value as determined from recent sales of comparable properties in the same market. Because there are not many sales of shopping centers and because of the many differences between shopping center size, age and location, the market value approach is not normally used for this kind of property. Third is the income approach method determined by the property’s net earning power based on the capitalization of the net income.... In Maricopa County, the initial valuation of a new shopping center is done by the cost method. The third method, the income approach, is frequently used after a shopping center has been in operation long enough to make this *564method feasible. The information and data necessary to perform ah income analysis is solely with the possession of the owner of the shopping center and this information must be provided by the owner to the assessor before the assessor can perform an income analysis and arrive at a market value based upon the income meth-od____ [T]his method can be advantageous for some shopping centers----
Grossman, 123 Ariz. at 224, 599 P.2d at 180 (emphasis added). This language foreshadowed that of the statute. Had the legislature wanted to allow the use of the comparable sales method in an unconventional manner, it would have said so.
It is thus plain that our statute is based upon the science of appraisal techniques known at the time of its enactment. The income approach still dominates.1 See Ga-brellian & Jessourian Assocs. v. Borough of Oakland, 11 N.J. Tax 310, 315 (1990), which quotes Friedman 1978 and says that “[a]s shopping centers are bought and sold on the basis of their net income, ... the expert’s comparable sales are devoid of any probative utility.”
If the comparable sales method is not a “factor,” then what are “factors?” The answer is to be found in an examination of the income method itself. While subsection B of the statute refers to one of the factors, the capitalization rate, there are many other factors involved in investment property that an appraiser must consider when using the income approach to value. Friedman 1968 at 37; William L. Ventólo, Jr. and Martha R. Williams, Fundamentals of Real Estate Appraisal 165 (1990) [hereinafter Ventólo and Williams]; American Institute of Real Estate Appraisers, The Appraisal of Real Estate 321 (1978) [hereinafter American Institute]. Under subsections B and C, the taxpayer submits income and expense information. But “[b]efore net income is ready to be processed into an indication of value, the appraiser must consider several important factors bearing on value.” Friedman 1968 at 40-41 (emphasis added). These are: (1) trends or cyclic swings in international, national, city, and neighborhood activity; (2) decentralization, particularly of a central city business district; (3) rising or falling costs in construction; (4) supply and demand of mortgage financing; (5) economic supply and demand in the real estate market for the type of property under appraisement; (6) the remaining economic life of the property; and (7) the physical condition of the property. Id at 41.
Several other “factors” “affect the appraisal of the shopping center”: (1) single ownership of the land; (2) the size of the site; (3) zoning; (4) topography; (5) subsoil conditions; (6) availability of utilities; (7) the level of real estate taxes; (8) distance from competing shopping centers; (9) accessibility; and (10) land cost. Friedman 1968 at 403-405.
And the following factors require “special emphasis”: (1) the property must be valued as an aggregate; (2) a market survey must be prepared; (3) sales of commercial properties in the vicinity cannot be used as a basis of valuation of the center; and (4) valuation of the land must be based on capitalization of annual residual net income. Id at 405.
“Various national, regional and local factors might also have to be analyzed in deriving market rent.” Ventolo and Williams at 165 (emphasis added). Are rents going up or down? Are we coming out of a recession or going into one?
There is another sense in which the use of the word “factors” has been part of the historical development of the income approach. Present worth factor tables are referred to as “Inwood factors.” “Hoskold factors” are “reciprocals of the building capitalization rate when based upon sinking-fund recapture.” American Institute at 316, 318.
*565The point of this is that the words “other valuation factors” in subsection D can mean any number of factors within the income method. These could include market factors to the extent otherwise allowed by the income method. But unless words are infinitely elastic, “other valuation factors” cannot include the entirely unexpressed comparable sales method.
In sum, I read “other valuation factors” to mean other valuation factors within the income method, and not, as the majority does, as other valuation “methods.” This, it seems to me, comports more closely with the structure of § 42-147. It gives meaning to subsection D without destroying the legislature’s intent to use the replacement cost less depreciation method or the income method for the valuation of shopping center property.
Finally, the majority develops its theory against the backdrop of constitutional concerns over the unique treatment given shopping center property. I do not share those concerns. “Value” is simply that figure derived by the application of the method selected by the legislature for a particular class of property.2 The legislature has the power to classify property for taxation purposes in ways that are rational. These appraisal treatises and Grossman suggest that the two methods the legislature chose are precisely those that are applicable to shopping center property, and that the comparable sales method is not. Thus, I see no constitutional issues here. I say this because if the legislature is of the view that neither the majority nor I have properly understood § 42-147, it is free to amend it to make its purpose more manifest.
If the comparable sales method ever achieves acceptance in the appraisal community for the valuation of shopping centers, it is the function of the legislature, and not this court, to amend the relevant statute. I respectfully dissent.
. Contrary to the majority’s assertion, the inapplicability of the comparable sales approach is not just because of the absence of sales, but also because of the incomparability of those sales. Shopping centers are not similar enough to support the comparable sales method. Grossman, 123 Ariz. at 224, 599 P.2d at 180; Friedman 1978 at 444. Too much depends upon a variety of factors such as the presence of competition, the mixture of tenants, the terms of leases, the cost of construction, the terms of mortgages, parking areas, and operating expenses. Friedman 1978 at 444.
. And thus the implausible example of paying $50 million for an asset that generates income as though it were worth $13 million does not trouble me. Ante, at 561, 892 P.2d at 1350.