dissenting.
The majority (1) prohibits the St. Louis Board of Education from asserting collateral estoppel;1 (2) declines to consider the Board’s argument that a statute precludes the additional tax relief St. Louis City attempted to grant; and (3) concludes that the Missouri Constitution permits perpetual tax relief for the same property.
The majority’s conclusion is contrary to the consistent understanding of the constitutional provision at issue by the People of Missouri, the General Assembly, this Court, and the Attorney General. I would hold that *534the City’s attempt to grant additional tax relief beyond 25 years is unconstitutional and would reverse the judgment below.
Article X, section 7 of the Constitution provides:
For the purpose of encouraging forestry when lands are devoted exclusively to such purpose, and the reconstruction, redevelopment and rehabilitation of obsolete, decadent or blighted areas, the general assembly by general law may provide for such partial relief from taxation of the lands devoted to any such purpose, and of the improvements thereon, by such method or methods, for such period or periods of tone, not exceeding twenty-five years in any instance, and upon such terms, conditions, and restrictions as it may prescribe. ...
Mo. Const. art. X, § 7. The key language reads: “the general assembly ... may provide for ... relief from taxation of ... lands ... and of the improvements thereon ... for such period or periods of time, not exceeding twenty-five years in any instance_” In my view, the best reading is that the phrase “in any instance....” modifies the word “lands” — not the phrase “period or periods of tone.”
The majority ignores the comma between the phrases, and rewrites the Constitution to read: “for such period or periods of time not exceeding twenty-five years in any instance.” In fact, a comma separates the phrase “for such period or periods of time,” from “not exceeding twenty-five years in any instance.” The comma means that the phrase “not exceeding twenty-five years in any instance” refers to the word “lands”. Section 7 thus permits a piece of land to receive one or more periods of relief, but not totaling more than 25 years.
Even more compelling than the plain language is the consistent reading of § 7 as a 25-year limit on tax relief by the People of Missouri, the General Assembly, this Court, and the Attorney General.
I.
In a statewide election in 1976, the People amended § 7 to add a proviso after the above-quoted original § 7:
provided, however, that in the case of forest lands, the limitation of twenty-five years herein shall not apply.
Mo. Const. art. X, § 7. Clearly, the People wanted to permit forest lands to receive tax relief for longer than 25 years; the constitutional amendment means that relief for more than 25 years was not already permitted. See Wollard v. City of Kansas City, 831 S.W.2d 200, 203 (Mo. banc 1992). Thus, urban “obsolete, decadent or blighted areas” are still subject to the 25-year limitation for each plot of land.
The People adopted § 7 in the 1976 amendment with the purpose of: “the reconstruction, redevelopment, and rehabilitation of obsolete, decadent, or blighted areas.” Mo. Const, art. X, § 7. Perpetual relief rewards failure ever to complete reconstruction, redevelopment, and rehabilitation. This Court should reject perpetual relief as inconsistent with § 7’s overall purpose, as passed by the People.
II.
The General Assembly has also consistently treated § 7 as a 25-year limit on tax relief. Section 353.110, under which the original relief was granted for 25 years, provides:
After a period totaling not more than twenty-five years, such real property shall be subject to assessment and payment of all ad valorem taxes, based on the full true value of the real property; ....
§ 353.110.2, BSMo 1986 (emphasis added). By requiring payment of all ad valorem taxes and assessment at fall value, the plain language of § 353.110 prohibits relief beyond 25 years for the same property. Cf. Annbar Associates v. West Side Redevelopment Corp., 397 S.W.2d 635, 653 (Mo. banc 1965).
Here, the City attempted to grant an additional ten-year relief under § 99.700, which permits partial tax relief upon certification by the land clearance for redevelopment authority. Section 99.700 is subject to the 25-year limit in § 353.110. Sections 99.700 and 353.110 were last amended in 1986 by House Bill 1327. Laws of Missouri 1986, 490. House Bill 1327, in fact, contained no provi*535sions other than the amendments to these "two sections. Id. The General Assembly’s plain language in § 353.110 thus governs § 99.700. Once a piece of property has received the full 25 years of relief under § 353.-110, further relief under § 99.700 is not available.
Even if there were some ambiguity between the differing provisions in § 353.110 and § 99.700, established rules of statutory construction would restrict § 99.700 from authorizing an additional ten-year relief. First, tax exemptions are strictly construed against the party claiming the exemption, who has the burden of proving entitlement to an exemption. Wetterau, Inc. v. Director of Revenue, 843 S.W.2d 365, 367 (Mo. banc 1992). Since neither § 99.700 nor § 353.110 clearly expresses any intent to permit further relief after 25 years, this Court should not construe them to permit it.
Second — and most clearly — a court has a special obligation to harmonize sections passed simultaneously and appearing next to each other in the same bill, and as the only components of that bill. See Cascio v. Beam, 594 S.W.2d 942, 946 (Mo. banc 1980). There is no reason to interpret the statutes to be in conflict by reading § 99.700 as additional relief after 25 years when § 353.110 requires payment of all taxes at full value.
The General Assembly certainly viewed § 7 as constituting a 25-year limit on tax relief, under § 99.700 and § 353.110 in its last enactment. The majority’s contention that its interpretation defers to the General Assembly is refuted by the Assembly’s express statement in its most official act: a law.
III.
This Court has previously held that § 7 applies to the land at issue, not to a particular owner. Annbar Associates v. West Side Development Corp., 397 S.W.2d 635, 653 (Mo. banc 1965). In Annbar, interpreting the Constitution, this Court prohibited one plot of land from receiving over 25 years of tax relief, from a change in the identity of owners. Id. Similarly, in this case, a change in the identity of the statute does not alter the Constitution’s limit of 25 years of tax relief.
IV.
In 1970, the Attorney General expressed the opinion that relief for more than 25 years is not permitted under § 7. Op.Atty.Gen. No. 344, Danforth, 10-28-70. While this Court need not accept the Attorney General’s interpretation, neither should we ignore its impact. See Mesker Brothers Industries, Inc. v. Leachman, 529 S.W.2d 153, 158 (Mo.1975). Even if wrong on the merits, the opinion shows that the General Assembly proposed, and the People approved, a constitutional amendment based on the understanding that the Constitution imposes a 25-year limit. See Nicolai v. City of St. Louis, 762 S.W.2d 423, 426 (Mo. banc 1988).
V.
Until today’s opinion, the People, the General Assembly, this Court and the Attorney General have understood § 7 as a 25-year limit on tax relief for the same property. I would follow, not abandon, this common understanding and reverse the judgment.
. Because the parties did not brief the issue, this is not the case to decide the propriety of applying nonmutual collateral estoppel against government entities.