OPINION BY
Judge SIMPSON.
Asserting that a local school district filed an improperly selective tax assessment appeal, Raymond R. Vees and Kathleen A. Vees (collectively, Taxpayers) appeal an order of the Court of Common Pleas of Carbon County (trial court) that increased the assessed value of Tax Parcel No. 16-56-A67 (Property) for the 2003 tax year. We affirm.
Carbon County performed a countywide reassessment effective for tax year 2001. The Property, which consists of 85 acres of unimproved land, was assigned a fair market value of $92,250.00. In April 2002, Taxpayers purchased the Property for $170,000.00.
In August 2002, the Palmerton Area School District (School District) appealed to the Carbon County Board of Assess[745]*745ment Appeals (Board), contending the Property’s fair market value should be $170,000.00. After hearing, the Board increased the Property’s fair market value to $161,900.00. This had the effect of increasing the assessed value of the Property from $45,000.00 to $80,950.00 after application of the County’s predetermined ratio of 50%.
Taxpayers appealed to the trial court. Their appeal did not challenge the constitutionality of any provision of The Fourth to Eighth Class County Assessment Law (Law)1 or of The General County Assessment Law (GCAL).2 Reproduced Record (R.R.) at 8a-9a, 37a-40a. Rather, Taxpayers alleged that the assessment was excessive and, “the assessment violated the requirement of uniformity and the same is discriminatory, and the assessment violates due process and equal protection of laws to [Taxpayers].” R.R. at 9a.
At a de novo hearing before the trial court, Taxpayers offered to prove the School District brings tax assessment appeals where a purchase price exceeds the current assessed value by $15,000.00. Taxpayers also offered to prove the intent of the School District in taking multiple tax assessment appeals is to correct what it perceives as economic valuation problems within its jurisdiction. The trial court sustained a relevance objection. R.R. at 49a-56a, 114a-15a, 133a.
Regarding value of the Property, the School District presented the testimony of a real estate appraiser who opined the fair market value was $180,000.00. Raymond R. Yees testified on behalf of Taxpayers and confirmed he and his wife purchased the Property for $170,000.00.
The School District also presented the testimony of the County’s Chief Assessor. He testified the County’s common level ratio,' as determined by the State Tax Equalization Board (STEB), was 45%, and the County’s predetermined ratio, as determined by the County Commissioners, was 50%.
At the conclusion of the hearing, the trial court adopted the Board’s fair market value of $161,900.00. After application of the County’s predetermined ratio of 50%, the trial court set the assessed value at $80,950.00. Taxpayers appealed.3
Taxpayers argue the appeal which prompted the Board to increase the Property’s assessed value constitutes a spot reassessment in violation of the uniformity clause of the Pennsylvania Constitution and the equal protection clause of the United States Constitution.4 They also challenge the trial court’s exclusion of their proffered evidence. Significantly, [746]*746Taxpayers do not claim any statutory provision is unconstitutional. Nor do they challenge any fact found by the trial court, such as the finding of fair market value or of the applicable ratios.
I.
As to the evidentiary issue, we conclude the trial court did not abuse its discretion in declining to receive evidence on the School District’s general appeals strategy or on the School District’s intent in taking other appeals. Here, the appeal was limited to valuation of the Property. Importantly, Taxpayers did not challenge the constitutionality of any statute and did not attempt to offer comparables evidence, which may have invited consideration of process beyond that pertaining to their Property.
A taxpayer alleging that the administration of a tax violates its rights to be taxed uniformly with others of its class must demonstrate deliberate, purposeful discrimination in the application of the tax before constitutional safeguards are violated. Appeal of Armco, Inc., 100 Pa. Cmwlth. 452, 515 A.2d 326 (1986). Assuming for the current discussion only that an appeal constitutes administration of a tax, Taxpayers here needed to prove the School District deliberately and purposefully discriminated against them in taking the appeal, or the Board deliberately and purposefully discriminated against them in handling the appeal. The School District’s practice and intent in other cases does not clearly establish deliberate discrimination in this appeal, and the information tends to confuse the issues. Therefore, the trial court could properly conclude the danger of confusion outweighed the probative value of the proffered evidence. Pa.R.E. 403.
II.
A.
As to the substantive issue, Taxpayers contend the Board violated their rights when on appeal it changed the value of the Property. They argue that Section 602.1 of the Law,5 72 P.S. § 5453.602a, limits the circumstances in which a board may change assessed valuation on property, and a recent sale is not among those circumstances.
Taxpayers’ argument is without merit. Here, neither the County nor the Board initiated any revaluation of the Property; rather, the process was initiated by School District’s appeal. This distinction is significant for two reasons. First, the revaluation was not initiated by a body possessing the power to prepare or revise assessment rolls, value property, change the value of property, or establish the predetermined ratio,6 all essential elements of the assessment process. See Millcreek Township Sch. Dist. v. Erie County Bd. of Assessment Appeals, 737 A.2d 335 (Pa.Cmwlth. 1999).
Second, the statutory provision upon which Taxpayers rely deals with assessment procedures, not appeals. A different statutory provision specifically addressing appeals controls here. Section 702 of the Law expressly covers “any appeal of an assessment” and, among other things, requires the Board to make a finding as to the market value of the property as of the date such appeal was filed. 72 P.S. § 5453.702(b)(1).
As a matter of law, the Board’s compliance with this statutory mandate is not deliberate, purposeful discrimination. [747]*747This is especially true here, where the constitutionality of Section 702 of the Law is not challenged.
. Otherwise, Taxpayers did not attempt to prove that the Board deliberately and purposefully discriminated against them, nor do they advance that argument now. The record only contains information that the Board acted on an appeal and made a decision based on information submitted to it. Therefore, it is not surprising that the trial court made no findings regarding deliberate, purposeful discrimination by the Board. Further, it is clear that Taxpayers did not prove constitutional violations by the Board.
B.
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OPINION BY
Judge SIMPSON.
Asserting that a local school district filed an improperly selective tax assessment appeal, Raymond R. Vees and Kathleen A. Vees (collectively, Taxpayers) appeal an order of the Court of Common Pleas of Carbon County (trial court) that increased the assessed value of Tax Parcel No. 16-56-A67 (Property) for the 2003 tax year. We affirm.
Carbon County performed a countywide reassessment effective for tax year 2001. The Property, which consists of 85 acres of unimproved land, was assigned a fair market value of $92,250.00. In April 2002, Taxpayers purchased the Property for $170,000.00.
In August 2002, the Palmerton Area School District (School District) appealed to the Carbon County Board of Assess[745]*745ment Appeals (Board), contending the Property’s fair market value should be $170,000.00. After hearing, the Board increased the Property’s fair market value to $161,900.00. This had the effect of increasing the assessed value of the Property from $45,000.00 to $80,950.00 after application of the County’s predetermined ratio of 50%.
Taxpayers appealed to the trial court. Their appeal did not challenge the constitutionality of any provision of The Fourth to Eighth Class County Assessment Law (Law)1 or of The General County Assessment Law (GCAL).2 Reproduced Record (R.R.) at 8a-9a, 37a-40a. Rather, Taxpayers alleged that the assessment was excessive and, “the assessment violated the requirement of uniformity and the same is discriminatory, and the assessment violates due process and equal protection of laws to [Taxpayers].” R.R. at 9a.
At a de novo hearing before the trial court, Taxpayers offered to prove the School District brings tax assessment appeals where a purchase price exceeds the current assessed value by $15,000.00. Taxpayers also offered to prove the intent of the School District in taking multiple tax assessment appeals is to correct what it perceives as economic valuation problems within its jurisdiction. The trial court sustained a relevance objection. R.R. at 49a-56a, 114a-15a, 133a.
Regarding value of the Property, the School District presented the testimony of a real estate appraiser who opined the fair market value was $180,000.00. Raymond R. Yees testified on behalf of Taxpayers and confirmed he and his wife purchased the Property for $170,000.00.
The School District also presented the testimony of the County’s Chief Assessor. He testified the County’s common level ratio,' as determined by the State Tax Equalization Board (STEB), was 45%, and the County’s predetermined ratio, as determined by the County Commissioners, was 50%.
At the conclusion of the hearing, the trial court adopted the Board’s fair market value of $161,900.00. After application of the County’s predetermined ratio of 50%, the trial court set the assessed value at $80,950.00. Taxpayers appealed.3
Taxpayers argue the appeal which prompted the Board to increase the Property’s assessed value constitutes a spot reassessment in violation of the uniformity clause of the Pennsylvania Constitution and the equal protection clause of the United States Constitution.4 They also challenge the trial court’s exclusion of their proffered evidence. Significantly, [746]*746Taxpayers do not claim any statutory provision is unconstitutional. Nor do they challenge any fact found by the trial court, such as the finding of fair market value or of the applicable ratios.
I.
As to the evidentiary issue, we conclude the trial court did not abuse its discretion in declining to receive evidence on the School District’s general appeals strategy or on the School District’s intent in taking other appeals. Here, the appeal was limited to valuation of the Property. Importantly, Taxpayers did not challenge the constitutionality of any statute and did not attempt to offer comparables evidence, which may have invited consideration of process beyond that pertaining to their Property.
A taxpayer alleging that the administration of a tax violates its rights to be taxed uniformly with others of its class must demonstrate deliberate, purposeful discrimination in the application of the tax before constitutional safeguards are violated. Appeal of Armco, Inc., 100 Pa. Cmwlth. 452, 515 A.2d 326 (1986). Assuming for the current discussion only that an appeal constitutes administration of a tax, Taxpayers here needed to prove the School District deliberately and purposefully discriminated against them in taking the appeal, or the Board deliberately and purposefully discriminated against them in handling the appeal. The School District’s practice and intent in other cases does not clearly establish deliberate discrimination in this appeal, and the information tends to confuse the issues. Therefore, the trial court could properly conclude the danger of confusion outweighed the probative value of the proffered evidence. Pa.R.E. 403.
II.
A.
As to the substantive issue, Taxpayers contend the Board violated their rights when on appeal it changed the value of the Property. They argue that Section 602.1 of the Law,5 72 P.S. § 5453.602a, limits the circumstances in which a board may change assessed valuation on property, and a recent sale is not among those circumstances.
Taxpayers’ argument is without merit. Here, neither the County nor the Board initiated any revaluation of the Property; rather, the process was initiated by School District’s appeal. This distinction is significant for two reasons. First, the revaluation was not initiated by a body possessing the power to prepare or revise assessment rolls, value property, change the value of property, or establish the predetermined ratio,6 all essential elements of the assessment process. See Millcreek Township Sch. Dist. v. Erie County Bd. of Assessment Appeals, 737 A.2d 335 (Pa.Cmwlth. 1999).
Second, the statutory provision upon which Taxpayers rely deals with assessment procedures, not appeals. A different statutory provision specifically addressing appeals controls here. Section 702 of the Law expressly covers “any appeal of an assessment” and, among other things, requires the Board to make a finding as to the market value of the property as of the date such appeal was filed. 72 P.S. § 5453.702(b)(1).
As a matter of law, the Board’s compliance with this statutory mandate is not deliberate, purposeful discrimination. [747]*747This is especially true here, where the constitutionality of Section 702 of the Law is not challenged.
. Otherwise, Taxpayers did not attempt to prove that the Board deliberately and purposefully discriminated against them, nor do they advance that argument now. The record only contains information that the Board acted on an appeal and made a decision based on information submitted to it. Therefore, it is not surprising that the trial court made no findings regarding deliberate, purposeful discrimination by the Board. Further, it is clear that Taxpayers did not prove constitutional violations by the Board.
B.
Taxpayers attempted to prove the School District violated their rights by filing a selective appeal based on its perception that the Property was undervalued. They rely on cases discussing spot reassessments.
We conclude, however, that the cases Taxpayers cite do not control. On the contrary, a statutory provision allowing school districts the same appeal rights as property owners, and cases applying the provision, compel the conclusion that the School District did not deliberately and purposefully discriminate against Taxpayers.
1.
As a general proposition, selective reassessment or “spot reassessment” by a body clothed with the power to prepare or revise assessment rolls, value property, change the value of property, or establish the predetermined ratio is improper. Althouse v. County of Monroe, 159 Pa. Cmwlth. 467, 633 A.2d 1267 (1993) (applying Law, county assessor’s office improperly increased valuations of properties in one subdivision); O’Merle v. Monroe County Bd. of Assessment Appeals, 95 Pa.Cmwlth. 141, 504 A.2d 975 (1986) (applying Law, county assessor’s office improperly increased assessment of one property to include improvements); Callas v. Armstrong County Bd. of Assessment, 70 Pa.Cmwlth. 272, 453 A.2d 25 (1982) (applying Law, county assessor properly corrected assessment of one property as part of countywide accuracy check). See also McCrady v. Bd. of Property Assessment, 827 A.2d 522 (Pa.Cmwlth.2003), appeal denied, 577 Pa. 691, 844 A.2d 554 (2004) (applying Second Class County Assessment Law and GCAL, county assessor improperly revised assessment of one property); Radecke v. York County Bd. of Assessment Appeals, 798 A.2d 265 (Pa.Cmwlth.2002) (applying Second Class A and Third Class County Assessment Law, county appraiser improperly revalued one property to include improvements). Similarly, such a body must use the same methodology to value all property in a county, and it may not reassess values in part of the county. City of Lancaster v. County of Lancaster, 143 Pa.Cmwlth. 476, 599 A.2d 289 (1991) (applying Second Class A and Third Class County Assessment Law and GCAL). These cases all deal with activity initiated by an entity enjoying the power of assessment. Collectively, the cases provide that assessors and the board cannot reassess less than an entire county except as correction of errors or as otherwise specifically provided by statute. None of these cases concerns an alleged defect in an appeal.
In addition, Taxpayer’s rely on Wilkinsburg Sch. Dist. v. Bd. of Property Assessment, 797 A.2d 1034 (Pa.Cmwlth.2002), appeal denied, 573 Pa. 681, 822 A.2d 706 (2003). In Wilkinsburg, Allegheny County, a county of the second class with significant assessment problems, instituted a countywide freeze on all assessments. By [748]*748formal resolution, the board adopted the freeze except in specified circumstances. Despite the freeze, a county assessor reassessed a property without the occurrence of one of the recognized exceptions. On appeal by the property owner, the board rolled back the assessment. A school district appealed to the trial court, which concluded the board properly applied its resolution and entered partial summary judgment for tax years during which the freeze applied. We affirmed, holding the trial court did not err in supporting uniform adherence to the freeze resolution.
Wilkinsburg is easily distinguished from the current case both legally and factually. Unlike the legal issue in the current case, which raises an alleged defect in an appeal, in Wilkinsburg we addressed an improper reassessment initiated by the county. We decided any result other than uniform application of the freeze would have the practical effect of sanctioning an improper spot reassessment by the county. Moreover, the unusual facts in Wilkinsburg, which included assessment freezes pending countywide reassessment, distinguish that case from the present controversy.
2.
As noted, the present controversy was initiated not by an assessor’s action but by an appeal. Therefore, the statutory provisions covering appeals control. Section 706 of the Law, 72 P.S. § 5453.706, provides:
The corporate authorities of any county, borough, town, township or school district, which may feel aggrieved by any assessment of any property or other subject of taxation for its corporate purposes, shall have the right to appeal therefrom, in the same manner, subject to the same procedure and with like effect as if such appeal were taken by a taxable with respect to his assessment, and in addition may take an appeal from any decision of the board or court of common pleas as though it had been a party to the proceedings before such board or court, even though it was not such a party in fact.
Interpreting this clear legislative directive, this Court holds school districts which feel aggrieved by any property assessment have the right to appeal in the same manner, subject to the same procedure and effect, as if the appeal was pursued by an individual property owner. Richland, Sch. Dist. v. County of Cambria Bd. of Assessment Appeals, 724 A.2d 988 (Pa.Cmwlth. 1999).
Millcreek, 737 A.2d 335, is instructive. There, an en banc panel of this Court specifically rejected a property owner’s argument that the prohibition against spot reassessments applies to appeals by school districts. In Millcreek, -the county did not initiate a new assessment; rather, a school district initiated an appeal, which the board denied. The trial court also dismissed the appeal, concluding to permit the school district to appeal would violate the uniformity clause. We reversed, concluding that school districts lack the power to assess, and therefore the prohibition against spot reassessment does not apply to appealing school districts.
Additionally, in Millcreek we rejected the argument that absent a “triggering event” listed in the applicable statute,7 the school district could not appeal a property assessment. We held school districts retain the same appeal and procedural due [749]*749process rights as individual property owners. As such, neither a property owner nor a taxing district is prohibited from appealing an assessment event even though no triggering event occurred. The “[e]xercise of appeal rights by both the [school] district and the property owner, will ensure that the uniformity required by our state constitution is maintained.” Id. at 339.
As a matter of law, the School District’s use of the statutory appeal mechanism available uniformly to all interested parties does not amount to deliberate, purposeful discrimination. This is especially true here, because Taxpayers do not challenge the constitutionality of Section 706 of the Law. Moreover, pursuant to Millcreek, the filing of a tax assessment appeal by a school district does not amount to an improper spot assessment.
As a matter of fact, the trial court made no findings regarding deliberate, purposeful discrimination by the School District. Considering the foregoing, Taxpayers did not prove a constitutional violation by the School District taking this appeal.
3.
In Millcreek we did not decide whether the result of an appeal by a school district can create an unconstitutional lack of uniformity. Thus, we did not decide whether a successful appeal by a school district where property values are increased has an unconstitutional effect. We now hold that the result here does not create an unconstitutional lack of uniformity.
A taxpayer should pay no more and no less than his proportionate share of the cost of government. Deitch Co. v. Bd. of Property Assessment, Appeals and Review of Allegheny County, 417 Pa. 213, 209 A.2d 397 (1965). Implementation of this principle would require that an owner’s assessment be reduced so as to conform to the common level of assessment in the taxing district. Id.
The constitutional mandate requiring uniformity is satisfied when the taxing authority assesses all property in the taxing district at the same percentage of its actual value. Appeal of Johnstown Assocs., 494 Pa. 433, 431 A.2d 932 (1981). Application of such a uniform ratio assures each taxpayer will be held responsible for its pro rata share of the burden of local government. Id.
Section 704(c) of the Law, 72 P.S. § 5453.704(c), applies to appeals and provides in pertinent part:
(c) The court, after determining the market value of the property pursuant to subsection (b)(1), shall then apply the established predetermined ratio to such value unless the corresponding common level ratio determined pursuant to subsection (b)(2) varies by more than fifteen per centum (15%) from the established predetermined ratio, in which case the board shall apply the respective common level ratio to the corresponding market value of the property.
Here, the fair market value of the Property was reduced by a uniform ratio, the County’s predetermined ratio. That ratio is “the ratio of assessed value to market value established by the board of county commissioners and uniformly applied in determining assessed value in any year.” Section 102 of the Law, 72 P.S. § 5453.102. As there is no contest to the accuracy or applicability of this ratio, its use satisfies the requirement of uniformity in the appeal.
Further, we are guided by our recent decision in Baechtold v. Monroe County Bd. of Assessment Appeals, 804 A.2d 713 (Pa.Cmwlth.2002), where a uniformity challenge was raised. As here, the prop[750]*750erty owners did not contest the market value of their property or the county’s established predetermined ratio. Also as here, they did not prove the statutory mechanism was unreasonable or otherwise violates any constitutional right. We rejected the uniformity challenge in Baech-told, as we reject it here.
Accordingly, we affirm the trial court’s order.
ORDER
AND NOW, this 8th day of February, 2005, the order of the Court of Common Pleas of Carbon County is AFFIRMED.