¶ 94. (dissenting). I agree with the circuit court's excellent decision. I conclude, as did the circuit court after reviewing all the evidence presented at trial, that the City of Madison properly assessed Adams's billboards using the income approach, after considering various approaches to valuation. The obvious purpose of an outdoor sign is for public display in a desirable location. As the circuit court stated, "A billboard does not generate income sitting in a warehouse; its value is a function of its permit and its location. That income-generating capacity is inextricably intertwined with the billboard and its value must be captured if, as Wisconsin law requires, the property is to be assessed at its full market value."
¶ 95. Accordingly, the personal property tax assessments challenged in the instant case are valid assessments, and I therefore dissent.
H
¶ 96. I begin with the method of assessment used by the City. The majority opinion, like the circuit court, correctly states the law regarding the various methods of personal property tax assessment. Both the circuit court and the majority opinion correctly conclude that *486the City was entitled to use the "third tier" assessment methods to assess the billboards.1
¶ 97. The majority opinion is also correct that when conducting a third tier assessment, the income approach "cannot be considered as the sole controlling factor in determining value of either real or personal property."2 "[A]n assessor must determine market value from the best information the assessor can practicably obtain, considering all elements which collectively have a bearing on the value of the property."3 When the assessor uses more than one approach to assessment, he must reconcile the values determined by the various approaches. However, when other approaches are properly rejected and only one approach is used, obviously no reconciliation is needed.4
*487¶ 98. As the majority opinion observes, the purpose of requiring assessors to consider all elements that bear on the value of property is to prevent "skewed appraisals due to aberrant market conditions."5 The majority opinion properly recognizes, however, that the limiting factor is that data may not be available or appropriate to develop any and all approaches.6 According to the majority opinion, "an assessor must have the ability to discount, even disregard, factors that do not really bear on the value of a property."7 I wholeheartedly agree. And the present case falls right into this situation.
¶ 99. Unfortunately, the majority opinion does not apply the rules of assessment it espouses. Indeed, after stating that an assessor may disregard factors that do not bear on the value of the property, the majority opinion shifts, concluding that the rule requiring an assessor to consider all elements that bear on the market value would be nullified if the assessor were permitted "to reject all approaches and factors other than an income approach" because he "deemed unreliable" other approaches.8
¶ 100. Which is it? Either the assessor can disregard other approaches when they are inappropriate, or he cannot.
¶ 101. The record developed in the circuit court is clear that the City considered several third tier assess*488ment methods. The record demonstrates that after considering a variety of approaches, the assessor had a sufficient basis to use the income approach for the assessment and to disregard other approaches as not reliable and as producing a skewed fair market value. The other approaches were disregarded after careful consideration; none was rejected out of hand, as the majority opinion states.9 The circuit court opinion details the record demonstrating the City's careful analysis in rejecting the cost approach. I conclude that the assessor's rejection of approaches and factors that were not reliable in the instant case comports with long-standing assessment principles articulated in the cases and the rule stated in the majority opinion.10
*489¶ 102. The City determined that there were no recent arms-length sales.11 Adams did not proffer evi*490dence of reasonably comparable sales.12 The majority opinion in effect concedes that although the City attempted to use comparable sales, neither the City nor Adams offered any at trial.13
¶ 103. The two approaches at issue in the instant case are the "cost approach" and the "income approach." The cost approach is a measurement of the replacement cost of the property. The income approach is a measurement of the amount of income the property will generate over its useful life.14
¶ 104. The City assessor considered the cost approach and determined that it was not a reliable way to determine the fair market value. In the City's supplemental report regarding the 2002 and 2003 assessments, relying on the Wisconsin Property Assessment Manual and citing to expert authority, the City describes its valuation methodology as considering, but rejecting, the cost approach as follows:
Due to the lack of complete, accurate cost data, the cost approach is not considered a reliable approach to value and is not considered in this valuation. Most sources agree that the cost approach does not reflect the fair market value of outdoor advertising signs.
*491The cost approach is not considered a rehable indicator of value for the subject property due to the following reasons:
The age of the improvements and constant maintenance and upkeep makes it almost impossible to estimate reproduction or replacement cost and appropriate depreciation and obsolescence.
It is very difficult or almost impossible to estimate appropriate soft costs, site procurement costs and entrepreneurial profits which are needed to put the billboard into productive use as required by the Wisconsin Property Assessment Manual.
All sources reviewed considered the cost approach to be the least reliable approach to value for outdoor advertising signs, the lowest value indicator, and not an accurate reflection of market value.
The materials of the sign do not influence its value. Rather, location is of paramount importance in outdoor advertising. A location of a particular billboard may have a value over and above its nuts and bolts value. In this sense, in the billboard industry, it is virtually impossible to separate location from the structure.
The sign structure and appropriate rights associated with the sign structure are inextricably intertwined and cannot be properly valued using the cost approach.
¶ 105. Thus, the record in the trial court is clear that the City did not use the income approach as the sole controlling factor in determining the value of personal property, and it is clear that the majority opinion is misleading in suggesting that the City assessor rejected the cost approach "out of hand."15
¶ 106. Other states allow use of the income approach. The critics of the income approach recognize *492that the income approach is valid. The criticisms are primarily that the income approach is difficult to implement.16
¶ 107. The journal article relied upon by the majority opinion to conclude that the cost approach is the emerging trend is totally unconvincing.17 The article has to be read knowing that both authors "specialize in representing owners in property tax assessment matters."18 They conclude that the cost approach is the best approach for tax assessment purposes.19
¶ 108. There are several more substantive reasons not to take this article very seriously. The authors' *493conclusion about any emerging trend toward the cost approach is not supported by the evidence presented in the article.
¶ 109. The authors surveyed a mere six states.20 One of the six states was Wisconsin, which is not described as adopting any of the three approaches.21 Two of the six states expressly allow an income approach. In California, income value may be used; if the cost approach is used a cost new value is given to the property, depreciation is subtracted, and the value of land is determined (using comparable sales) and added 22 In Ohio, cost is prima facie evidence of value unless evidence to the contrary is brought by the taxing authority or taxpayer.
¶ 110. Regardless, the examples from the six states are unconvincing because four of the six states discussed, California, Ohio, Texas, and North Carolina, provide nothing more than examples of recommended guidelines by an agency with no authority to mandate appraisal approaches. They do not discuss what is actually happening in those states.23 Thus we cannot determine from the article the billboard assessment rules in the six states or any other states.
¶ 111. Furthermore, any normative conclusions reached by the authors must be rejected in Wisconsin because the authors' view of the proper approach to valuation conflicts with Wisconsin law. The authors reject the "sales approach" as unreliable.24 In Wisconsin, however, it has long been the rule that the "sales *494approach," valuing the property based on recent or comparable sales, is the best approach to valuation. Only when sales information is not available, as in the instant case, may an assessor proceed to the third tier approaches.25
¶ 112. Moreover, other commentators reject the normative conclusions in this article. A commentator relied upon by the majority opinion,26 who is a member of a private law firm and apparently represents con-demnees rather than condemnors and at least one billboard company, concludes that the cost approach is appropriate for determining the value of billboards in only rare circumstances. This commentator has observed that there are several problems with the cost approach:
The cost approach has at least three major shortcomings:
-It does not reflect market thinking: Buyers and sellers of outdoor advertising do not consider the replacement cost of a sign, minus depreciation, as an accurate estimate of value when they purchase signs.
-Depreciation may be impossible to estimate: Because sign companies are continually refurbishing sign structures, standard methods of estimating physical depreciation cannot be applied to outdoor signs. In addition, cost estimating services do not develop age-life tables for signboards as they do for other categories of real estate. Moreover, economic obsolescence attributable to negative external influences is extremely difficult, if not impossible, to estimate.
-Replacement cost may not reflect value: The replacement cost of a sign can be estimated quite readily. The actual cost to build a sign can be determined from *495contractors' estimates or bids. However, the cost of acquiring the site for sign usage must also be reflected in the cost estimate. Companies continually acquire new sites for outdoor advertising. To complicate matters further, associated costs for items such as entrepreneurial profit must be estimated.
Because of these serious shortcomings, use the cost approach only in the rarest of circumstances.27
¶ 113. The same commentator also espouses the virtue of using the income approach for determining the value of billboards, contending that the income approach encompasses the full value and nature of the billboard:
The true value of an outdoor advertising sign depends on a host of factors. Many of these characteristics make the valuation of billboards similar to the appraisal of commercial real estate generally. Signs are purchased for their locations, the signboard structures themselves, and the land leases that run with the sites on which the signs stand. These interests are similar to the real estate interests involved in the purchase of an apartment building, office building, or commercial center, which usually include the location, the physical structure(s), and the right to use the land under the lease agreement. Attributes such as advertising potential are related to locational interests. Location is of prime importance to all real estate assets, whether the real estate is residential, commercial, or industrial. This is equally true of the interests in outdoor advertising signboards.
*496The similarities between billboards and other commercial properly interests, such as office buildings, restaurants, and the like, suggest that billboards are properly viewed as real property.28
¶ 114. The expert opinions cited by the City in its supplemental report on the 2002 and 2003 assessments support the proposition that the cost approach is unreliable for billboards. An article written by one of Adams's expert witnesses explains that the income approach appropriately captures the value of a billboard because, unlike other businesses, the income-producing capacity cannot be separated from the physical structure:
It is... incorrect to assert that the income approach reflects the "business" value of a billboard. The expense data, which include all operating and management costs, effectively eliminate the "business" component from the income figures. ... An outdoor advertising structure is not a restaurant or a fast food outlet, where a separate and distinct business activity is conducted such as selling food and beverages. All activities of a sign owner relate directly to its being rented to a tenant-advertiser, a purely real estate related function.29
*497¶ 115. Taking into account the fact that the City considered and rejected approaches other than the income approach and the fact that the income approach is a proper approach to assessing property for tax purposes, I conclude that the City's decision to use only the income approach was proper.
¶ 116. I must now consider whether the City properly applied the income approach. The circuit court concluded, and I agree, that the City properly applied the income approach, including the "inextricably intertwined" concept. I agree with the circuit court that the City had eliminated from its income approach any elements improper in assessing the billboards as personal property.30
¶ 117. In the real property context, this court has held that "certain business value may in fact be 'appended' to the real estate rather than personal to the owner."31 This value is appended to real property when it is inextricably intertwined with the land.32
*498¶ 118. The majority opinion asserts that the "inextricably intertwined" concept is not applicable here because the billboard permit is "a right or privilege appertaining to real property and thus falls within the definition of 'real property1 in Wis. Stat. § 70.03."33 The majority opinion asserts that the "inextricably intertwined" concept is not applicable here because the billboard permit is an interest in real property and the income attributable to the permits is properly included in the real property tax assessment, not the personal property tax assessment. Therefore, concludes the majority opinion, the permit cannot be inextricably intertwined with personal property (the billboard).
¶ 119. The majority opinion remarkably also explains that a billboard permit is both real property and intangible personal property.34
*499¶ 120. Although the cases addressing the inextricably intertwined rule are real property cases, I agree with the circuit court that the same rationale applies to personal property taxation.35 "[T]he 'key to the analy*500sis'... 'is whether the value is appended to the property, and is thus transferable with the property, or whether it is, in effect, independent of the property so that the value either stays with the seller or dissipates upon sale.' "36
¶ 121. It is clear from the case law, from the record in the instant case, and from a commonsense perspective that the cash value (the fair market value) of a billboard is based on income, which is inextricably intertwined with the billboard permit. In Vivid, Inc. v. Fiedler, 219 Wis. 2d 764, 781, 580 N.W.2d 644 (1998) (an eminent domain case in which no one argued that the cost approach alone was adequate to evaluate the fair market value of the billboard), this court explained that
the value of the sign is derived largely from the location of the sign. Therefore, "all right, title and interest in and to the sign and ... leasehold relating thereto" must include not only the value of the sign structure and leasehold value, but also the value of the location.
It is therefore not the permit but the valuation of the location encompassed in the permit that is included in the assessment of a billboard.
¶ 122. The record in the instant case supports the conclusion that the value of the physical structure of *501the billboard is inextricably intertwined with the location of the billboard, which is governed by the permit.
¶ 123. First, as the City's supplemental report stated, the materials that make up the billboard do not influence its value. Rather, the value is tied to (that is, inextricably intertwined with) the location of the billboard and, thus, the permit.
¶ 124. Second, on cross-examination, Adams's expert witness agreed that the sign permit is inextricably intertwined with the purpose of the sign and that the permit is the vehicle by which income is derived:
Q So the permit is inextricably, if you will, entwined with the existence and intended purpose of the sign, wouldn't you say?
A Yes.
Q You can buy and sell sign permits, right?
A Yes.
Q If you were to be the negotiator, the appraiser, the whatever you want to call it who is analyzing the sale price of that permit, what would you — you would not look at the dollar value of the physical piece of paper, would you?
A Oh, no, I would look at the marketable value of the permit.
¶ 125. Third, Adams's general manager testified that the value of a billboard and the value of a permit are inextricably intertwined:
Q If you pay $1,500 for a permit to have a sign in Madison, does that get you, your company, more than $1,500 worth of value?
*502A Absolutely
Q Okay. Explain why.
A Because having a permit is like gold, and when we have one we can at that point put up a bulletin and make a lot more than $1,500.
Q That's the critical piece of the value of a sign?
A Yeah. I wouldn't be in business if I didn't have any permits.
Q Is the most critical component of a billboard the value of the permit?
A Yes.
Q And without a permit is there value to a billboard?
A No.
Q With a permit is there value?
A Yes.
In other words, structures and permits are bought and sold on the basis of what income is expected to be generated by the billboard with the permit.
¶ 126. Adams's general manager further testified that the income-producing capacity of billboards is tied to the permit, not the physical sign structure, and the permit is transferable to a subsequent purchaser.
Q Now, in the billboard industry is there a market for just used sign structures?
A Not much of one.
Q Is there a market for billboard leaseholds?
A Absolutely.
*503Q Do people buy or do companies buy and sell billboards leaseholds that don't have billboards on them?
A Yes.
Q Are you in the business, meaning Adams of course, do you have a warehouse full of sign parts that you sell to others as sign parts on a regular basis?
A No, sir.
¶ 127. Finally, a commonsense perspective supports the conclusion that the value of a billboard is inextricably intertwined with the billboard permit. Without a permit, a billboard is nothing more than a pile of metal and wood. It seems implausible that personal property that brings in tens or hundreds of thousands of dollars a year in income has a fair market value limited to the cost of the pile of metal and wood. If Adams were to sell its billboards, it surely would get more than the cost of the materials. How, then, can the market value of the billboard be just the cost of the materials?37 I conclude that it cannot.
¶ 128. I further conclude, as did the circuit court, that the City did not err in its assessment of Adams's billboards using the income approach and that the City's *504application of the income approach properly subtracted value unrelated to the billboards themselves.
¶ 129. After following the twists and turns of the majority opinion, I conclude that on remand the City can use the income method it has used and reach the same result it reached previously.
HH HH H — I
¶ 130. I now consider Adams's state constitutional challenge to the assessment.
¶ 131. Adams contends that the City's use of the income approach to assess its billboards, but not other commercial properties, violates the Uniformity Clause of the Wisconsin Constitution. Adams's contention is without merit.
¶ 132. The Uniformity Clause, Wis. Const, art. VIII, § 1, provides that "[t]he rule of taxation shall be uniform ... ."38 The uniformity clause requires that all *505property be taxed according to the market value of the property.39
¶ 133. There is no requirement, however, that a uniform method or approach to determining market value be used for all property. The Uniformity Clause does not require that each and every property be valued in the same manner. Rather, it requires that, whatever the valuation of the property, the fraction of the value to be paid in taxes must be the same:
The methods of determining true, current value necessarily differ in the absence of significant sales, but when once the true value is arrived at, each dollar's worth of one sort of property is liable for exactly the same tax as a dollar's worth of any other sort of property, and to assess real property at a different fraction of the value than personalty is error.40
¶ 134. This court has explained that "there can be variations in the mechanics of property assessment or tax imposition so long as the resulting taxation shall be borne with as nearly as practicable equality on an ad valorem basis with other taxable property."41
¶ 135. There is no allegation that the City assessed different properties at different rates. Using the income approach alone for certain properties and not for others does not violate the Uniformity Clause. This *506case is about nothing more than the proper way in which to determine fair market value. The uniformity clause is not implicated.
¶ 136. For the reasons set forth, I would affirm the judgment of the circuit court upholding the City's assessment of Adams's billboards. I therefore dissent.
¶ 137. I am authorized to state that Justice ANN WALSH BRADLEY joins this opinion.Majority op., ¶ 47.
Bischoff v. City of Appleton, 81 Wis. 2d 612, 619, 260 N.W.2d 773 (1978) (quoting State ex rel. I.B.M. Corp. v. Bd. of Review, 231 Wis. 303, 312, 285 N.W 784 (1939)); see majority op., ¶ 48; 1 Property Assessment Manual for Wisconsin Assessors, ch. 7, at 7-28 ("The appraiser should consider all three approaches when estimating the value of a property. However, all three approaches may not be developed in an appraisal because a sufficient amount of data may not be available or, due to the specific property characteristics, the approach may be considered less reliable in estimating market value." (second and third emphasis added)); see also Waste Mgmt. of Wis., Inc. v. Kenosha County Bd. of Review, 184 Wis. 2d 541, 558, 516 N.W.2d 695 (1994) ("Income may never be the sole basis for an assessment of property.").
Waste Mgmt., 184 Wis. 2d at 558.
1 Property Assessment Manual, ch. 7, at 7-28 ("If more than one approach is developed in the appraisal, the individual value estimates must be reconciled into one final value estimate for the property.... The final value estimate may be the value estimate derived from one of the approaches or may be a careful *487reconciliation of the applicable approaches.") Thus the majority opinion's emphasis, ¶ 54, on reconciliation in the instant case is irrelevant.
Majority op., ¶ 51.
Majority op., ¶¶ 52-54.
Majority op., ¶ 53 (emphasis added).
Majority op., ¶ 55.
Majority op., ¶ 55.
See, e.g., Waste Mgmt., 184 Wis. 2d at 557 ("[A]n assessor must determine market value from the best information the assessor can practicably obtain, considering all elements which collectively have a bearing on the value of the property. Such elements, as identified by various decisions of this court, include, among others, cost, depreciation, replacement value, income, industrial conditions, location and occupancy, sales of like property, book value, amount of insurance carried, value asserted in a prospectus, and appraisals procured by the owner." (citations omitted)); State ex rel. Kesselman v. Bd. of Review for Village of Sturtevant, 133 Wis. 2d 122, 129, 394 N.W.2d 745 (1986) (same); Rosen v. City of Milwaukee, 72 Wis. 2d 653, 663, 242 N.W.2d 681 (1976) (same); State ex rel. Park Plaza Shopping Center, Inc. v. Bd. of Review for City of Madison, 61 Wis. 2d 469, 474, 213 N.W.2d 27 (1973) (same); Superior Nursing Homes, Inc. v. City of Wausau, Bd. of Review, 37 Wis. 2d 570, 575, 155 N.W.2d 670 (1968) (same); State ex rel. Garton Toy Co. v. Town of Mosel, 32 Wis. 2d 253, 259-260, 145 N.W.2d 129 (1966) (same); State ex rel. Mitchell Aero, Inc. v. Bd. of Review of City of Milwaukee, 74 Wis. 2d 268, 277, 246 N.W.2d 521 (1976) ("The method of valuation generally has been to assess both personal and real property on the basis of its fair market value; i.e., the *489amount it will sell for upon arms-length negotiation in the open market, between an owner willing but not obliged to sell, and a buyer willing but not obliged to buy."); Xerox Corp. v. DOR, 114 Wis. 2d 522, 527, 339 N.W.2d 357 (1983) (same); State ex rel. Geipel v. City of Milwaukee, 68 Wis. 2d 726, 733, 229 N.W.2d 585 (1975) ("Commonly stated, sec. 70.32(1) requires real estate to be assessed at its fair market value which has often been defined as the amount the property could be sold for in the open market by an owner willing and able but not compelled to sell to a purchaser willing and able but not obliged to buy."); State ex rel. Kesselman v. Bd. of Review for Village of Sturtevant, 133 Wis. 2d 122, 128-129, 394 N.W.2d 745 (1986) ("In the absence of such sales, the assessor may consider all the factors collectively which have a bearing on value of the properly in order to determine its fair market value. ... Among these factors are costs, depreciation, replacement value, income, industrial conditions, location and occupancy, sales of like property, book value, amount of insurance carried, value asserted in a prospectus and appraisals procured by the owner."); State ex rel. Markarian v. City of Cudahy, 45 Wis. 2d 683, 686, 173 N.W.2d 627 (1970) (same); Buildings Development Co. v. City of Milwaukee, 225 Wis. 357, 359-60, 274 N.W 298 (1937) (quoting State ex rel. North Shore Development Co. v. Axtell, 216 Wis. 153, 155-157, 256 N.W 622 (1934)) ("Elements besides income proper to consider in assessing property are ... 'costs, depreciation, replacement value, earnings, industrial conditions,' and 'location of the property relative to the business section of the city.1"); State ex rel. Flambeau Paper Co. v. Windus, 208 Wis. 583, 587, 243 N.W. 216 (1932) ("[I]n fixing valuation [take] into account cost, depreciation, replacement value, earnings, industrial conditions, and sales of... properties. These are factors entering into sale value, and proper to consider in judging it."); Duesterbeck v. Town of Koshkonong, 2000 WI App 6, ¶ 27, 232 Wis. 2d 16, 605 N.W.2d 904 ("[Section] 70.32(1), stats.,... requires assessment based on real estate's fair market value, using the most rehable information that the assessor can practicably obtain.").
See majority op., ¶ 38.
See majority op., ¶¶ 39-47, ¶ 43 n.10, ¶ 46 n.ll.
Majority op., ¶ 47. The comparable sales approach has been described as "fraught with numerous difficulties, all of which militate against use of this approach for property tax valuation of billboards." Cris K. O'Neall & Bradley R. Marsh, Trends in the Property Tax Valuation of Commercial Outdoor Advertising Structures, J. of Prop. Tax Assessment & Admin. 5, 7 (vol. 1, issue 2, 2004).
Majority op., ¶ 35.
See majority op., ¶ 55.
See, e.g., James Wagner & David Baker, The Valuation of Outdoor Advertising Structures:. A Mass Appraisal Approach, Assessment Digest, July/Aug. 1991, at 4 ("Advantages of using the cost approach in the valuation of off-premise signs are: (1) the ease of application; (2) the ability to determine the value of the structure irrespective of location, income, and expenses attributable to the business as opposed to the structure; and (3) the availability of cost data."); Charles F. Floyd, Outdoor Advertising Signs and Eminent Domain Proceedings, Real Estate Appraiser & Analyst, Summer 1990, at 16 ("Traditionally, the cost approach is the appraisal technique that has been utilized to value outdoor advertising signs in eminent domain proceedings. It has been accepted by the courts as a valid technique, and it has been accepted by most courts as the ONLY valid technique for valuing outdoor advertising signs. The sole exception arises when evidence indicates that the sign cannot be relocated within the entire market area. In this situation several courts have ruled that some variation of the income approach may be used.").
In the instant case, however, the assessor was able to determine the market value of the billboards using the income approach and the signs cannot be relocated easily in Madison.
See majority op., ¶ 29.
O'Neall & Marsh, supra note 13, at 5.
Id. at 11.
Id. at 8-11.
Id. at 11.
See id. at 8-9, 10.
Id. at 8-9, 10-11.
Id. at 7.
Majority op., ¶¶ 34, 37.
Majority op., ¶ 46.
Jill S. Gelineau, Valuation of Billboards in Condemnation, 19 No. 4 Practical Real Estate Lawyer 23, 30-31 (July 2003) (also observing that the value of a billboard is tied to location, permit, and physical structure and that billboards are arguably real property, not personal property, in eminent.domain cases).
Gelineau, supra note 27, at 27.
Rodolfo J. Aguilar, The Appraisal of Off-Premise Advertising Billboards, Right of Way, September/October 2000, at 12 (publication of the Int'l Right of Way Ass'n, http://www. irwaonhne.org/).
For further discussion of the relative benefits of the income approach compared to the cost approach in determining the value of a billboard, see also other authorities cited by the City in the supplemental report, Donald T. Sutte, The Appraisal of Outdoor Advertising Signs 41 (1994) (stating same reasons as Gelineau to explain why cost approach is inappropriate for billboards); Ron L. Nation & Donald E Oehlrich, The Valuation of Billboard Structures, The Appraisal Journal, October 1999, *497at 412 (publication of the Appraisal Institute, http://www. appraisalinstitute.org/) (discussing inadequacy of cost approach in determining value of billboard).
The majority opinion concludes that "the same methods of appraisal may be used in eminent domain as are used in appraising personal property for tax purposes, provided care is taken to exclude from a personal property tax assessment any value attributable to elements other than tangible personal property." Majority op., ¶ 90.
Waste Mgmt., 184 Wis. 2d at 564.
See ABKA Ltd. P'ship v. Bd. of Review of Village of Fontana-On-Geneva-Lake, 231 Wis. 2d 328, 336, 344, 603 N.W.2d 217 (1999); Waste Mgmt., 184 Wis. 2d at 564; State ex rel. *498N/S Assocs. v. Bd. of Review of Village of Greendale, 164 Wis. 2d 31, 54-55, 473 N.W.2d 554 (Ct. App. 1991).
Majority op., ¶ 59. See also majority op., ¶ 64 ("[A] billboard permit falls within the definition of real property."); ¶ 66 ("[A] billboard permit should be assessed as a right or privilege appertaining to real property under Wis. Stat. § 70.03."); ¶ 79 ("Regardless of our conclusion that billboard permits are real property...."); ¶ 85 ('We conclude that because billboard permits are real property, as defined in Wis. Stat. § 70.03, the income attributable to them is properly included in the real property tax assessment, not the personal property tax assessment").
The majority opinion states that it does not want to "leave the impression that the answer is 'no'" to the question of whether a billboard permit is " 'intangible' within the meaning of Wis. Stat. § 70.112(1)," that is, whether a billboard permit is intangible personal property. Majority op., ¶¶ 65-66.
I assume that because the majority does not want to leave the impression that the answer is "no" because it would be "misleading," it must conclude that the answer is "yes."
*499The explanation in the majority opinion that permits are, as a general rule, intangible personal property excluded from property taxation is untenable. See majority op., ¶¶ 65-77. This conclusion does not comport with the text of Wis. Stat. § 70.112(1), defining personal property that is exempt from property taxation, or the cases interpreting the statute.
Wisconsin Stat. § 70.112(1) exempts from property taxation "[mjoney and all intangible personal property, such as credit, checks, share drafts, other drafts, notes, bonds, stocks and other written instruments." In State ex rel. Dane County Title Co. v. Board of Review, City of Madison, 2 Wis. 2d 51, 62, 85 N.W.2d 864 (1957), this court applied the principle of ejusdem generis and concluded that " 'written instruments' as used in sec. 70.112(1), Stats., refers to writings that evidence rights and obligations of things involving money credits."
The majority opinion does not explain how a permit can be classified as a "money credit." Indeed, in explaining that a permit is generally non-taxable intangible personal property under § 70.112(1), the majority does not apply Dane County Title, the foundational supreme court case interpreting the meaning of the phrase "intangible personal property" in § 70.112(1).
Although real property was at issue, in N/S Associates, 164 Wis. 2d at 54, the court of appeals discussed the inextricably intertwined rule as applying to "property" generally. This court cited N/S Associates favorably regarding the inextricably intertwined rule in ABKA Limited Partnership, 231 Wis. 2d at 336.
Both personal and real property are assessed on the basis of fair market value and the same methods of valuation, that is, sales, cost, and income, are used for both types of property.
Another reason to apply the inextricably intertwined rule to billboards is that a billboard, though classified in Wisconsin as personal property, appears to be like real property. Jill S. Gelineau argues that in eminent domain cases, billboards should be valued as real property, not personal property. *500Gelineau, supra note 27, at 30-31 (observing that the value of a billboard is tied to location, permit, and physical structure and that billboards are arguably real property, not personal property, in eminent domain).
ABRA Ltd. P’ship, 231 Wis. 2d at 337 (quoting N/S Assocs., 164 Wis. 2d at 54); see also id. at 336 ('Whether an income interest may be captured in a property assessment hinges on whether the value appertains to the property. A value that appertains to property is one that is transferable with the property.").
See Gelineau, supra note 27, at 30-31 (noting problems with the cost approach, including the fact that buyers and sellers of billboards do not consider replacement cost to reflect the value of the billboard).
Gelineau observes that "the market value of a sign in place may be 10 or 15 times the construction cost" and that "the value of a billboard lies in its location, permit, and physical structure —not the operating business." Gelineau, supra note 27, at 30, 31.
Gottlieb v. City of Milwaukee, 33 Wis. 2d 408, 424, 147 N.W.2d 633 (1967), distills the guiding principles of the Uniformity Clause as follows:
1. For direct taxation of property, under the uniformity rule there can be but one constitutional class.
2. All within that class must be taxed on a basis of equality so far as practicable and all property taxed must bear its burden equally on an ad valorem basis.
3. All property not included in that class must be absolutely exempt from property taxation.
4. Privilege taxes are not direct taxes on property and are not subject to the uniformity rule.
5. While there can be no classification of property for different rules or rates of property taxation, the legislature can classify as between property that is to be taxed and that which is to be wholly exempt, and the test of such classification is reasonableness.
*5056. There can be variations in the mechanics of property assessment or tax imposition so long as the resulting taxation shall be borne with as nearly as practicable equality on an ad valorem basis with other taxable property.
(Emphasis added.)
State ex rel. Baker Mfg. Co. v. City of Evansville, 261 Wis. 599, 609, 53 N.W.2d 795 (1952).
Id.
Gottlieb, 33 Wis. 2d at 424.