2566 ARTICLE 81.

Where land belonging to the United States government and exempt from taxation,
was conveyed to a dry dock company upon condition that a dry dock be constructed
and that United States have a perpetual right to the use of same, and providing for
a reverter under certain conditions, the interest of the dry dock company in the
land and dock is taxable under this section. Baltimore Dry Dock Co. v. Baltimore,
97 Md. 103.

Where a railroad company held real property under a city ordinance providing
for a formal lease for ninety-nine years, from city to company, company was held
to be substantial owner and taxable on the leasehold interest. Appeal Tax Court v.
Western Maryland R. R. Co., 50 Md. 276.

As to the taxation of real estate of corporations, see also secs. 166 and 166A.

For cases involving assessment and taxation of easements, see Consolidated Gas
Co. v. Baltimore, 105 Md. 43; same, 101 Md. 542; United Rys. Co. v. Baltimore,
111 Md. 264.

Generally.

So long as a person continues to reside in a county, he is liable to taxation as a
citizen thereof; and if the levy for the year is completed before he removes there-
from, he is chargeable with the taxes for that year. Stoddert v. Ward, 31 Md. 566.

The purpose of the act of 1874, ch. 483, sec. 2, was not to abridge but to enlarge
the basis of taxation. Discrimination was made by said act as to the character of
the debts liable to taxation. A claim held to be a debt or private security, and
hence taxable. Buchanan v. Talbot County, 47 Md. 292.

State tax commission's decision as to whether a party is a resident of Md. is
not reviewable on appeal. Where three trustees, two of whom are non-residents
of Md., hold certain property for benefit of a resident of Md., the "legal title" is
not in a resident of Md., and beneficial interest is taxable under this section and not
under sec. 226. Sec. 226 does not prescribe a different measure or method of valua-
tion and assessment from sec. 2. The property from which an equitable interest
springs, rather than equitable interest therein, is taxed in cases where legal title is
in non-resident. Taxes generally are payable out of income or life tenant's interest—
exceptions to this rule. Notice of hearing before S. T. C. Humbird v. State Tax
Commission, 141 Md. 407.

Money on deposit with a trust company is not taxable under this section. Dis-
crimination made by this section as to debts which are taxable. See notes to sec. 225.
Baltimore v. Machen, 132 Md. 624.

The legislature having selected objects of taxation for state and local purposes, the
power of city of Baltimore to exempt property from taxation is not implied in, or
incident to, powers expressly granted that city. Jones v. Broening, Mayor, 135
Md. 242.

Under acts of 1841, ch. 23, and 1852, ch. 337, property held by a trustee residing
in this state is property assessed to such trustee, he being the holder of legal etate.
(See, however, sec. 226.) Latrobe v. Baltimore, 19 Md. 21. And as to the act of 1841,
ch. 23, see Gordon v. Baltimore, 5 Gill, 231.

The names of the owners of property must be ascertained before the assessment
- can be legally made. Tasker v. Garrett County, 82 Md. 154.

For cases involving effect of a repeal of a particular tax law upon assessments
and litigation pending thereunder, see Appeal Tax Court v. Western Maryland R. R.
Co., 50 Md. 275; Appeal Tax Court v. Patterson, 50 Md. 355.

For a case tracing history of law relative to taxation of property held for life
with a remainder over, see Williams' Case, 3 Bl. 254.

This section referred to in declaring invalid act of 1900, ch. 579, purporting to
apply to Allegany county. Baltimore City v. Allegany County, 99 Md. 5.

This section referred to in declaring invalid the general assessment act of 1874,
ch. 514. Maxwell v. State, 40 Md. 288.

This section referred to in construing acts of 1876, ch. 260, and 1878, ch. 413
(repealed and re-enacted by act of 1880, ch. 122). Appeal Tax Court v. Rice, 50 Md.
314. And see Bonaparte v. State, 63 Md. 474 (affirmed in 104 U. S. 592).

The proviso at the end of this section referred to in upholding the validity of
sec. 229, et seq. Hannis Distilling Co. v. Baltimore, 114 Md. 678. (And see Hannis
Distilling Co. v. Baltimore, 216 U. S. 285.)

This section referred to in construing sec. 98—see notes thereto. Simpson v.
Hopkins, 82 Md. 491.

This section referred to in construing sec. 225—see notes thereto. National Bank
of Baltimore v. Baltimore, 92 Fed. 239 (affirmed, 100 Fed. 24).

See secs. 4, 166 and 166A, and notes.

As to the remedy in case of an illegal assessment, see notes to secs. 162 and 168.