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DUGGAN, J. The defendant, City of Rochester (city), appeals a decision of the Superior Court (Morrill, J.) ruling that the city’s taxation of the plaintiff, Verizon New England, Inc. (Verizon), for its use and occupation of public property violated Verizon’s equal protection rights. We affirm.

Per Curiam. The State appeals orders of the Superior Court (Galway, J.) granting the plaintiffs’ declaratory judgment petition, finding the statewide property tax unconstitutional as applied, and requiring the State to repay the $880 million collected under the tax to date. We reverse.

The State appeals a decision of the Superior Court (Groff, J.) finding that the State has failed to fulfill its duty to define a constitutionally adequate education, failed to determine the cost of an adequate education, and failed to satisfy the requirement of accountability, and that House Bill 616 (the current education funding law) creates a non-uniform tax rate in violation of Part II, Article 5 of the New Hampshire Constitution. We affirm the trial court’s finding that the State has failed to define a constitutionally adequate education and stay consideration of its remaining findings.

The petitioners, Donald and Carol Latour, appeal year 2000 tax assessments by the respondent, City of Laconia (the “City”). Specifically, the petitioners claim that the City acted unlawfully and unreasonably when it classified certain trailers located on their property as buildings. See RSA 76:17. The New Hampshire Campground Owners’ Association (“NHCA”) filed an “Offer of Proof” as amicus curiae. The parties stipulated to the facts and the court heard argument based on those facts on September 27, 2002. All parties and the NHCA appeared. Because the court is satisfied that assessing the petitioner’s trailers as buildings is lawful and reasonable under the stipulated facts, the interests of justice would not be served by an abatement. RSA 76:17. Accordingly, the assessment by the respondent is AFFIRMED.

The petitioners are property owners from three different New Hampshire municipalities seeking equitable relief from the statewide education property tax. They filed this Petition for a Declaratory Judgment and for Injunctive Relief requesting that this Court declare the tax unconstitutional, enjoin the State from collecting and distributing this tax, and order the reimbursement of tax dollars already paid and collected under this taxation scheme.