Effective 1/1/11, new legislation eliminated distinction between mobile homes resting on permanent foundations and those not, with only the former being taxed as real property. New law now provides that all mobile homes and manufactured homes installed outside of mobile home parks on or after its effective date are to be assessed and taxed as real estate. "Grandfather clause" for mobile homes assessed and taxed as personal property prior to effective date of new law. Decision of Property Tax Appeal Board, finding that home was properly taxed as real property, was clearly erroneous. Legislation failed to address homes such as Petitioner's home that were not installed on or after effective date of new legislation and were not assessed and taxed in 2010. Such homes should be taxed as they would have been taxed prior to effective date of new legislation. Taxing Petitioners' home at higher rate for failure to comply with registration requirement is an arbitrarily harsh penalty. (CATES and BARBERIS, concurring.)