The top issue before us is whether, by authorizing a 'pro forma tax' based on purchase price and date rather than fair cash valuation as of January 1, G.L.c. 59, $2C, imposes an unconstitutional inconsistent or discriminatory tax on purchasers of real property from tax-exempt entities ...

We interpret G.L.c. 59, $2C, as a reasonable technique of effectuating the withdrawal, removal or termination of an exception when the subject property is no longer owned by a tax-exempt entity or used for a tax-exempt purpose. ...

We turn now to the query whether, if the Legislature may approve taxation when property is transferred from a tax-exempt entity or tax-exempt purpose, G.L.c. 59, $2C, that tax may be calculated, on a provisional basis, on the basis of the property's purchase price and date of sale rather than the fair cash valuation of the property as of January 1. The taxpayer argues that the different way of calculating the tax results in unconstitutionally disproportionate taxation and therefore, that it is entitled to full abatement of the tax assessment pursuant to $2C. We conclude, in the situation of this case, that the valuation method of $2C(a) is neither unreasonable, disproportionate, nor unconstitutional...

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