1802 REVENUE AND TAXES. ART. 81

Academy, 50 Md. 352; Appeal Tax Court v. Baltimore Cemetery Co., 50
Md. 435.

The fact that only a portion of a graveyard is occupied by graves, does
not limit the exemption from taxation to the portion so occupied. Appeal
Tax Court v. St. Peter's Academy, 50 Md. 353.

As to the taxation of corporate stock, see sec. 162; as to the taxation of
the gross receipts of railroads and other corporations, see sec. 167, et seq.;
as to county and municipal taxation upon the property of railroads, see
sec. 193.

As to the exemption from taxation of building associations, see sec. 211;
see also, art. 23, sec. 138.

Charitable and educational institutions.

Only the building or parts thereof which are reasonably necessary for
the corporate purposes of hospitals, charitable or benevolent institutions, etc.,
are exempt from taxation; any portion of the building devoted to other
purposes and rented out, and stocks and other Investments (though the
income be used for the support of the indigent), are taxable. Baltimore v.
Grand Lodge. 60 Md. 281; Appeal Tax Court v. St. Peter's Academy, 50
Md. 352; Appeal Tax Court v. Grand Lodge, 50 Md. 421; Eedemptlonists
v. Howard County, 50 Md, 449; Appeal Tax Court v. University of Mary-
land, 50 Md. 466. And see United Rys Co. v. Baltimore, 93 Md. 634.

A petition alleging that property is "held and used by the body corporate
for the purposes of piety and charity and for the instruction of young
females," does not bring the property within the exemption of this section
relative to hospitals, charitable institutions, etc. Such property is exempt
from taxation only to the extent that it is used for the benefit of the Indi-
gent and afflicted. Effect of the acts of 1876, ch. 260, and 1878, ch. 413.
Appeal Tax Court v. Baltimore Academy, 50 Md. 437. And see Appeal Tax
Court v. St. Peter's Academy, 50 Md. 339; Appeal Tax Court v. Grand Lodge,
50 Md. 421; Frederick County v. Sisters of Charity, 48 Md. 37.

As to the exemption from taxation of real estate and other property of
public libraries and reading rooms, see art. 77, sec. 119. As to the exemption
of money invested in trust for the public schools, see art. 77, sec. 176.

United States.

Property of the United States is not subject to state taxation. Van
Broklyn v. Anderson, 117 U. S. 151. And see M'Culloch v. Maryland. 4
Wheat. 316.

For a case involving the exemption from taxation of the personal property
of officers and agents of the federal government residing within the limits
of the naval academy grounds at Annapolis, see Chauvenet v. Anne Arundel
County, 3 Md. 259.

For lands of the United States in Maryland exempt from taxation, see
art. 96.

Generally.

Certain species or classes of property may be exempted from taxation
within reasonable limits, when the public interests so require. There must,
however, be no arbitrary discrimination between properties of the same
kind. Rules regulating exemptions. An exemption from taxation (by an
act of assembly) of a wharf owned by a religious corporation, held invalid
because it created an arbitrary discrimination, and also because It was in
conflict with article 3, section 33, of the state constitution. Baltimore v.
Starr Church. 106 Md. 286. And see Wilkens Co. v. Baltimore, 103 Md. 314:
Consolidated Gas Co. v. Baltimore, 101 Md. 554.

The legislature may in special cases grant an exemption from taxation
provided there be a consideration of some kind. If there is no consideration,
the exemption is a mere gratuity revocable at will. Appeal Tax Court v.
Grand Lodge, 50 Md. 428.

Exemptions from taxation are strictly construed and must be clearly
made out. Anne Arundel County v. Annapolis, etc.. R. R. Co., 47 Md. 592
(affirmed in 103 U. S. 1); Appeal Tax Court v. Rice, 50 Md. 303; Appeal
Tax Court v. Gill, 50 Md. 377; Bonaparte v. State, 63 Md. 474 (affirmed in