1864 REVENUE AND TAXES. [ART. 81

but all county or municipal taxes assessed upon said respective taxable
value of such respective shares of stock or shares shall be collected from
such bank, corporation or joint stock company, and when so paid shall
or may be charged by such bank, corporation or joint stock company to
the account of such stockholders or shareholders, respectively; but it is
expressly provided that all railroad companies working their roads by
steam power incorporated by, or under the laws of this State or any
other State, territory, District of Columbia or foreign country and doing
business in this State, shall respectively be subject to the annual state
tax upon their respective gross receipts within the State, prescribed by
section 167, which shall be paid and collected in a manner provided now
or hereafter by law, and the real and personal taxable property belong-
ing to such respective railroad companies shall be subject to county and
municipal taxation to this State in the respective counties and cities in
which such property is located; and where such respective railroad com-
panies are subject to such gross receipts tax for State purposes, their
shares of stock and real or personal property shall not be subject to
taxation for State purposes, and when such real and personal property
of such respective railroad companies is subject to county and munici-
pal taxation, their respective shares of stock shall not be subject to
county and municipal taxation, but the capital stock and property of all
other corporations which are subject to a tax upon their gross receipts,
other than railroad companies, shall be valued, assessed and taxed for
State, county and municipal purposes like the capital stock and prop-
erty of other corporations under this article.

Real estate.

The value of ground-rents owned by a corporation is not deducted as real
estate from the assessment of the company's capital stock. (See section
71). In making the abatement from the valuation of corporate stock on
account of real estate owned by the corporation, the commissioner is a minis-
terial officer; his limited powers. Baltimore v. Canton Co.. 63 Md. 233; State
v. Central Savings Bank, 67 Md. 296.

The value of real estate outside of Maryland owned by a corporation is
not deducted in valuing its capital stock for taxation. Assessment and levy,
held to have been made in time. American Coal Co. v. Allegany County, 59
Md. 193.

The machinery of a manufacturing corporation is included in the valua-
tion of its capital stock, and, hence, can not be taken into account in valuing
the company's real estate. Anne Arundel County v. Baltimore Sugar Refin-
ing Co.. 99 Md. 485. (See section 164).

In the light of this section and of sections 95, 153 and 159, improvements
upon real estate entirely completed in November, 1901 (owned-by a resident
corporation having a capital stock), are taxable for 1902, although such
Improvements were not assessed to the corporation on October 1, 1901,
as required by a local law. Skinner Dry Dock Co. v. Baltimore, 96 Md. 42.

The act of 1878, ch. 178. held to be in pari materia with the general assess-
ment law of 1876, ch. 260, and that In assessing the real estate of corpora-
tions under the former act, the county commissioners should conform to the
requirements of the latter. Under these acts separate tracts were required
to be valued separately, and a failure to comply with this requirement was
error on the part of the commissioners, unless the officers of the corporation
were at fault. Allegany County v. Union Mining Co., 61 Md. 550. And see
Philadelphia, etc., R. R. Co. v. Appeal Tax Court, 50 Md. 413.

As to the taxation of real estate, see also. sec. 2.