dissenting.
I dissent as to Division 1 of the majority opinion and the judgment affirming the trial court.
In my opinion the majority has taken a narrow, technical and erroneous view of the effect of the Act in question.
Construing the Act as a whole, it simply authorizes the imposition of an additional 1% sales tax on residents of a county, after approval in a referendum, with the proceeds from such tax to be used for reduction of ad valorem taxes.
The majority holds that the method used to accomplish such reduction, when there are municipalities within the county, of dividing the money obtained from thje sales tax between the county government and municipal government by creation of a special taxation district violates the uniformity requirement of Code § 2-4603. I disagree. This is simply the method used to accomplish the distribution of sales tax funds and consequent reduction of ad valorem taxes.
Perfect uniformity in imposition of taxes is impossible of achievement, anjl the method provided by this Act is fair and reasonable for rural and urban taxpayers.
The result of the majority decision is to destroy any semblance of uniformity of taxation throughout a given *348county, since urban taxpayers will now receive two reductions or rollbacks of ad valorem taxes, and rural taxpayers will receive only one.
I respectfully dissent.