hieving an increase in the rate of property tax. Hence, an
over-assessment constitutes no deprivation of property without due
process of law.[478] Likewise, land subject to mortgage may be taxed
for its full value without deduction of the mortgage debt from the
valuation.[479]

Real Property Taxes: Special Assessments.--A State may defray
the entire expense of creating, developing, and improving a political
subdivision either from funds raised by general taxation, or by
apportioning the burden among the municipalities in which the
improvements are made, or by creating, or authorizing the creation of,
tax districts to meet sanctioned outlays.[480] Where a State statute
authorizes municipal authorities to define the district to be benefited
by a street improvement and to assess the cost of the improvement upon
the property within the district in proportion to benefits, their action
in establishing the district and in fixing the assessments on included
property, after due hearing of the owners as required by the statute
cannot, when not arbitrary or fraudulent, be reviewed under the
Fourteenth Amendment upon the ground that other property benefited by
the improvement was not included.[481]

It is also proper to impose a special assessment for the preliminary
expenses of an abandoned road improvement, even though the assessment
exceeds the amount of the benefit which the assessors estimated the
property would receive from the completed work.[482] Likewise a levy
upon all lands within a drainage district of a tax of twenty-five cents
per acre to defray preliminary expenses does not unconstitutionally take
the property of landowners within that district who may not be benefited
by the completed drainage plans.[483] On the other hand, when the
benefit to be derived by a railroad from the construction of a highway
will be largely offset by the loss of local freight and passenger
traffic, an assessment upon such railroad is violative of due
process,[484] whereas any gains from increased traffic reasonably
expected to result from a road improvement will suffice to sustain an
assessment thereon.[485] Also the fact that the only use made of a lot
abutting on a street improvement is for a railway right of way does not
make invalid, for lack of benefits, an assessment thereon for grading,
curbing, and paving.[486] However, when a high and dry island was
included within the boundaries of a drainage district from which it
could not b