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Accordingly, in order to prevail in a petition for abatement, the petitioner must “prove that his tax was greater than it should have been with respect to the taxes of other property owners in the taxing district.” Ainsworth v. Claremont, 106 N.H. 85, 87 (1964).

Duval v. Manchester, 111 N.H. 375, 376, 286 A.2d 612, 613 (1971); Ainsworth v. Claremont, 106 N.H. 85, 87, 205 A.2d 356, 357 (1984).

See, e.g., Ainsworth v. Claremont, 106 N.H. 85, 88, 205 A.2d 356, 358 (1964) (“if each property is appraised at the same proportion to its full and true value,.

Plaintiff contends that these two facts lead to “an inescapable inference that the plaintiffs property was taxed at a higher ratio than other property generally in Bedford.” In denying an abatement, the master was bound by our holding in Ainsworth v. Claremont, 106 N.H. 85, 205 A.2d 356 (1964), which explained that in a tax abatement case: “The assessment of a general property tax looks to the raising of a certain amount of money in the taxing district.

Because the plaintiff must demonstrate that its property tax is “disproportionate to that of other property in general,” Ainsworth v. City of Claremont, 106 N.H. 85, 87, 205 A.2d 356, 358 (1964), quoting Rollins v. City of Dover, 93 N.H. 448, 450, 44 A.2d 113, 114 (1945), if the town does not stipulate to its proffered ratio of assessment, the plaintiff must then introduce evidence supporting the statistical validity of the State equalization ratio, or a proportionality study o

In an abatement case, however, the taxpayer need only “ ‘show that his valuation is disproportionate to *649 that of other property in general.’ ” Ainsworth v. Claremont, 106 N.H. 85, 87, 205 A.2d 356, 358 (1964), quoting from Rollins v. Dover, 93 N.H. 448, 44 A.2d 113 (1915).

The town next argues that the plaintiffs have failed to establish that the disputed assessment is disproportionately higher than that of other property in the town.

Duval v. Manchester, 111 N.H. 375, 286 A.2d 612 (1971); Freedman v. Exeter, 107 N.H. 163, 219 A.2d 275 (1966); Ainsworth v. Claremont, 106 N.H. 85, 205 A.2d 356 (1964).

To prevail before the board the plaintiffs had the burden of proving that the assessments on their properties were disproportionately greater than those on other property owners in Hanover.

I. In its appeal from the master's ruling, the city contends that under Ainsworth v. Claremont, 106 N.H. 85, 205 A.2d 356 (1964), plaintiff failed to prove disproportionality and therefore is entitled to no abatement.

W. Newhouse, Jr., Constitutional Uniformity and Equality in State Taxation 190-91 (1959); see Ainsworth v. Claremont, 106 N.H. 85, 88, 205 A.2d 356, 358 (1964); Brock v. Farmington, 98 N.H. 275, 279, 98 A.2d 162, 164-65 (1953).

Rollins v. Dover, 93 N.H. 448, 44 A.2d 113 (1945); Ainsworth v. Claremont, 106 N.H. 85, 205 A.2d 356 (1964); Freedman v. Exeter, 107 N.H. 163, 219 A.2d 275 (1966).

Plaintiffs argue that in their appeal to the tax commission defendants Hill and McAvoy stated their property was appraised in excess of the purchase price rather than that the assessment was “ disproportionately higher in relation to its true value than was the case as to other property in the city.