¶ 1. Mineral Point Valley Limited Partnership appeals from a judgment upholding a property tax assessment. The partnership contests the method the city assessor used to calculate the 2001 property tax on Fairview Heights Apartments, a subsidized housing project in the City of Mineral Point. Both the City of Mineral Point Board of Review and the trial court affirmed the assessment. On appeal, the partnership asserts that the assessor should have included an interest rate closer to the market interest rate of 8.75% when valuing the property, rather than its subsidized 1% rate. We conclude that a capitalization rate based on the subsidized interest rate is impermissible and reverse.
BACKGROUND
¶ 2. The partnership's real estate is a Rural Rental Housing Program project under § 515 of the federal 1949 Housing Act. This housing program provides low-income renters in rural areas with affordable housing by giving developers incentives to build there. One incentive is that the federal government provides developers interest credit for financing the property. In return, developers rent at below-market rates to people that meet the eligibility requirements of the program. The property is subject to numerous conditions and restrictions in return for the federal subsidy. For instance, the program restricts the owner from receiving *788annual income exceeding more than 8% of the owner's original equity payment for the life of the contract.
¶ 3. Here, the partnership's initial investment in the. property was 3% of the development cost. It obtained a fifty-year mortgage in 1990 at a commercial rate of 8.75%. In accordance with the housing program, the partnership pays a 1% interest rate and the federal government subsidizes the difference between the 8.75% and 1% rates.
¶ 4. For 2001, the city assessor used the 1% interest rate in his capitalization rate for the property, yielding a property value of $491,200. The partnership objected to the assessment. The board of review held a hearing and affirmed the assessment. The partnership appealed to the trial court, which remanded to allow the partnership to complete its cross-examination. After further hearing, the board reaffirmed the assessment, and the partnership appealed. The trial court affirmed the board. The partnership appeals.
STANDARD OF REVIEW
¶ 5. Because this is a certiorari review under Wis. Stat. § 70.47 (2001-02)1 we review the "record made before the board of review," not the trial court. Nankin v. Village of Shorewood, 2001 WI 92, ¶ 20, 245 Wis. 2d 86, 630 N.W.2d 141. We look for "any error in the proceedings of the board which renders the assessment or the proceedings void." Wis. Stat. § 70.47(13). We consider four factors:
(1) Whether the board acted within its jurisdiction; (2) whether the board acted according to law; (3) *789whether the board's action was arbitrary, oppressive or unreasonable, representing its will rather than its judgment; and (4) whether the evidence was such that the board might reasonably make the order or determination in question.
Nankin, 245 Wis. 2d 86, ¶ 20. More specifically, an assessment "made in accordance with the statutory mandate must be upheld if it can be supported by any reasonable view of the evidence." Id., ¶ 21. We will not make an independent assessment of the property; instead we remand to the board for further proceedings if any errors render the assessment void. Id.
DISCUSSION
¶ 6. The parties dispute a narrow issue: When an assessor uses the income approach to assess federally subsidized housing, should he or she use a capitalization rate which includes the subsidized or actual rate of mortgage interest? We recently addressed the valuation of federally subsidized property for tax purposes in Bloomer Housing Limited Partnership v. City of Bloomer, 2002 WI App 252, 257 Wis. 2d 883, 653 N.W.2d 309. In that case, we explained the law governing property valuation generally, and subsidized housing specifically:
The law governing property valuation for tax purposes is found in Wis. Stat. ch. 70. Wisconsin Stat. § 70.32(1) provides that real property be valued at the "full value" which could ordinarily be obtained at a private sale. "Full value" means the fair market value, that is, the amount the property would sell for in an arms-length transaction between a willing buyer not obligated to buy and a willing seller not obligated to sell. The statute also provides that property be valued *790according to the Wisconsin Property Assessment Manual, although use of the manual is improper when its provisions would not arrive at the "full value" of the assessed property.
In terms of subsidized housing, the assessment manual suggests three approaches to valuation: (1) the sales comparison approach, reflected in Wis. Stat. § 70.32(1), based on a recent arms-length sale of the property or a reasonably comparable one; (2) the cost approach, based on the expenses involved with creating the housing; and (3) the income approach, which values the property based on the income it generates.
Id., ¶¶ 14-15 (citations omitted).
¶ 7. The parties here, like those in City of Bloomer, agree that the income approach is the most appropriate method to value the property. "The income approach converts the future benefits likely to be derived from the property into an estimate of present value." Id., ¶ 16. The Wisconsin Property Assessment Manual instructs on how to use the income approach. 1 Wisconsin Property Assessment Manual 9-28 (rev. Dec. 2000) (hereinafter "manual"). One of the steps in applying the income approach is to derive a capitalization rate, which has included in it a mortgage rate. Generally, the manual directs assessors to "be aware of what is happening in the market. All of the information needed for the income approach is either obtained or verified by what the assessor finds in the marketplace." Manual at 9-8. With regard to federally subsidized housing specifically, the manual directs the assessor to consider mortgage terms and conditions in the income approach. Manual at 9-30.
¶ 8. Here, the parties dispute which mortgage rate must be included in the capitalization rate. The *791city contends that it should be the 1% subsidized rate because that is what the partnership actually pays on its mortgage. It also asserts that the subsidy benefits the property, not the tenants, and that the property value should reflect this benefit.2 The partnership contends that the mortgage rate should be closer to the stated market rate of 8.75% because numerous restrictions affect the property. It argues that the subsidy benefits the tenants and that an investor would not consider it a value-enhancing feature because of the restrictions on rents and annual profits.
¶ 9. Both parties assert that the manual permits the use of their respective rate, which might suggest that an assessor has discretion in how to account for the mortgage rate. But which mortgage rate the assessor uses significantly impacts the value of the property. Specifically, the 1% rate yields a property value of $491,200; whereas a rate of 9.5%3 yields a value of $178,100. The ratio between these values is more than two to one.
¶ 10. We conclude that an assessor cannot be free to choose between the mortgage subsidy rate and the mortgage market rate when using the income approach to valuing federally subsidized housing. Nor can a board of review choose to use the subsidized rate when *792making its determination as to the fair value of federally subsidized housing. We ordinarily grant great deference to assessors and boards of review. The amount at which property is valued can vary depending on matters of judgment and expertise. But the narrow issue we decide today is a matter of almost mathematical precision. A property cannot, at the same time be worth both $491,200 and $178,100, when the only difference in the values is whether a subsidized mortgage interest rate or a market interest rate is used. Two identical and adjacent real estate properties cannot have full values that differ by over 100% whether they lie in the same or adjoining municipalities.4
¶ 11. We must be particularly concerned with ensuring uniformity in the valuation method for federally subsidized housing because it may be more subject to diverse assessments than other properties. Because *793of restrictions on sale, less market data is available for property of this nature. Subsidized housing is not comparable to commercial, unencumbered properties. Manual at 9-30. Consequently, the income approach is usually the only method available and the assessor must value the properties individually, using actual income and expenses of the property. Metropolitan Holding Co. v. Board of Review, 173 Wis. 2d 626, 629, 495 N.W.2d 314 (1993).
¶ 12. We therefore turn to City of Bloomer for guidance on which mortgage rate fairly reflects the unique nature of federally subsidized housing. There, we upheld a trial court finding that the city's assessment based on the subsidized interest rate was excessive because it "failed to accurately account for" restrictions affecting the value of property. City of Bloomer, 257 Wis. 2d 883, ¶ 20. We reasoned that:
The beneficiaries of the subsidy, according to the manual, are the tenants. Nonetheless, the subsidy affects the property's value. Any potential buyer would reasonably consider the subsidy's value when determining the appropriate price. The subsidy, however, is not determinative. It must be weighed with all the other factors influencing value.
Id., ¶ 23. We also rejected the city's suggestion that the restrictions and conditions do not hinder the property value. Id., ¶ 23. We recognize that in Bloomer our review was of a trial court's determination of a claim for excessive assessment under Wis. Stat. § 74.37, as opposed to a certiorari review here. Still, in Bloomer, we affirmed the trial court's conclusion that an assessor had erred by using a subsidized interest rate to determine the fair market value of subsidized housing.
*794¶ 13. We conclude that if the use of a market rate was proper in City of Bloomer, the use of a subsidized interest rate here cannot be. Thus, the board of review did not act according to law when it accepted an assessment using the subsidized rate. Based on the result in City of Bloomer, we conclude that a capitalization rate based on a subsidized interest rate is impermissible, and that a market rate must be used, together with "all the other factors influencing value", to produce the fair value of the partnership's real estate. Id., ¶ 23. We follow Bloomer's conclusion that an assessment based on a subsidized interest rate was excessive. Cook v. Cook, 208 Wis. 2d 166, 190, 560 N.W.2d 246 (1997) (holding that the court of appeals may not overrule, modify, or withdraw language from a previously published decision of the court of appeals).
¶ 14. Judgment reversed with directions to remand to the board of review for proceedings consistent with this opinion.
By the Court. — Judgment reversed and cause remanded with directions.
All references to the Wisconsin Statutes are to the 2001-02 version unless otherwise noted.
We noted in City of Bloomer, 2002 WI App 252, 257 Wis. 2d 883, 653 N.W.2d 309, that the Wisconsin, Property Assessment Manual provides that the beneficiaries of the interest subsidy are the tenants, not the property. Id. at ¶ 23. It still does.
At the board hearing, the partnership's expert testimony was based on a 9.5% interest rate as the base rate for the property value calculation. The stated mortgage rate was 8.5%. The partnership's brief explains that the 9.5% value "implicitly includ[es] the recapture rate component, but before adding the tax rate."
When originally enacted in 1848, article VIII, section 1 of the Wisconsin Constitution provided: "The rule of taxation shall he uniform, and taxes shall be levied upon such property as the legislature shall prescribe." The first seven words of article VIII, section 1 still exist in today's constitution, though several exceptions to this rule have been added by constitutional amendment. The parties have not briefed the effect, if any, of this provision, and cases since 1848 have focused on uniformity within a taxing district. See Knowlton v. Supervisors of Rock County, 9 Wis. 378 (1859), Weeks v. The City of Milwaukee and Others 10 Wis. 186 (1860), and Nankin v. Vill. of Shorewood, 2001 WI 92, ¶ 20, 245 Wis. 2d 86, 630 N.W.2d 141. Since 1931, the entire state is a taxing district. See Wis. Const. art. VIII, § 10(3), Laws of 1931, ch. 4, § 2 and Wis. Stat. § 70.58. We leave until another day an inquiry into how the framers of our constitution would have viewed a variation of over 100% between adjacent and identical real estate located in the same district or two taxing districts.