ART. 81] EXEMPTIONS. 1801

respective uses thereof, nor to buildings, furniture, equipment or libra-
ries of incorporated educational or literary institutions, or to the ground
appurtenant thereto, in any city or incorporated town of this State
which are necessary to the respective uses thereof, nor to the buildings,
equipments and furniture of hospitals, asylums, charitable or benevolent
institutions of any county in this State, but not within any incorporated
city or town of this State, nor to the ground uot exceeding forty acres
appurtenant respectively thereto which are necessary for the respective
uses thereof, nor to the buildings, furniture, equipment or libraries of
incorporated educational or literary institutions or to the grounds
appurtenant thereto in any city or incorporated town of this State which
are necessary for the respective uses thereof, nor to the buildings, equip-
ment or libraries of incorporated educational or literary institutions
in any county of this State, nor to the ground not exceeding forty
acres appurtenant thereto which are necessary for the respective uses
thereof, nor to the personal property of any corporation by this State
and having capital stock divided into shares when said shares of said
corporation are subject to taxation under the laws of this State, nor to
the shares of stock of railroad companies working their roads by steam
power, incorporated by or under the laws of this State which are sub-
ject to taxation upon their gross receipts within this State, and to
county and municipal taxation upon their respective real and personal
property in the respective counties and cities of this State, in which
such respective properties are located, nor to the book accounts or bills
receivable or evidences of debt given for such accounts of any person
engaged in commercial business who is taxed upon the fair average
value of his stock of goods, wares and merchandise; and every person
engaged in commercial business shall be taxed upon the fair average
value of his stock in such business during the year preceding the assess-
ment upon which such tax is levied; and each and every one of said
exemptions from taxation shall be strictly construed.

Corporations.

The fact that the personal property of a domestic corporation whose stock
is subject to taxation in Maryland, is exempt under this section, does not
affect the liability to taxation of the personal property of a foreign corpora-
tion whose stock is taxable here—see notes to section 2. Wilkins Co. v. Balti-
more, 103 Md. 309. And see Consolidated Gas Co. v. Baltimore, 101 Md. 554.

The portion of this section exempting from taxation the personal property
of corporations whose capital stock is taxed, precludes the taxation of the
machinery of a manufacturing company as a part of its real estate. Anne
Arundel County v. Baltimore Sugar Co.. 99 Md. 485. (See section 164).

The act of 1870, ch. 394, exempting mortgages from taxation, held not to
exempt the capital stock of a corporation to the extent that it is invested
in mortgages. (As to taxes on mortgages, see sec. 187. et seq.) Emory v.
State, 41 Md. 57. And see Appeal Tax Court v. Gill, 50 Md. 377; Salisbury
Bldg. Assn. v. Wicomico County, 8G Md. 618.

While the land and buildings of a cemetery company under its charter
were exempt from taxation, such exemption was held not to extend to a
fund invested in stocks. Hence, the capital stock of the company was
exempt from taxation to the extent of its holdings in lands and buildings
only. State v. Baltimore Cemetery Co., 52 Md. 639. And see Appeal Tax
Court v. St. Peter's Academy, 50 Md. 345; Appeal Tax Court v. St. Peter's