REVENUE AND TAXES. 2641

would be the state tax on the said stock debts of the State and city of Balti-
more, so reported as aforesaid, and the latter amount shall be allowed
such corporation as a credit on its bill for state taxes; and the state tax
commission shall also report the assessed value of said stock debt of the'
city of Baltimore to the city collector of Baltimore city, and, in order to
ascertain the city tax, payable on the shares of capital stock of such cor-
poration to the city of Baltimore, the city collector shall deduct from the
assessed value of the shares of stock of such corporation, taxable in the
city of Baltimore, such proportion of the assessed value of said stock debt
of the city of Baltimore, so reported as aforesaid, as the shares of stock of
such corporation, taxable in the city of Baltimore, bear to the total out-
standing taxable shares of stock of such corporation, and the city tax cal-
culated upon the residue shall be the true amount of taxes payable to the
city of Baltimore on shares of capital stock of such corporation; and in
case of any shares of any bank or other corporation of this State upon
which the state and county or city taxes are levied and paid, or are pay-
able, by such bank or other corporation, being owned as aforesaid, by any
corporation having a capital stock divided into shares as an investment
of any part of its capital or surplus, the state tax commission, in assess-
ing the shares of such corporation, shall deduct the value, assessed accord-
ing to the laws of this State, of said shares of said bank or other corpora-
tion of this State so owned and reported as aforesaid, from the aggregate
value of all the shares of such corporation, in addition to and in the same
manner as the assessed value of real estate owned by such corporation is
deducted under the provisions of section 166; but no credit shall be al-
lowed under this section to any such corporation by reason of any invest-
ments on which the taxes are not paid or payable as aforesaid; nor by
reason of the ownership by said corporation or corporations of the stock
debt of the city of Baltimore issued after April 3, 1906, under the loans
authorized by chapters 274, 338 and 349 of the acts of the general assem-
bly of Maryland for 1904, known as the " Annex," " Park Extensions "
and " Sewer Loans," respectively, or any other loans that may have been
authorized since April 3, 1906, or that may be hereafter authorized by
the general assembly of Maryland; provided, that the provisions of this
section shall apply to the ownership by any such corporation of Baltimore
city burnt district loan stock, issue under chapter 468 of the acts of 1904,
the water loan, issued under chapter 333 of the acts of 1902, and the con-
duit loan, issued under chapter 246 of the acts of 1902, whether hereto-
fore or hereafter issued; nor shall such credit be allowed in any case
where the officer making such return for such corporation shall fail to
state in such return that said investments are owned by the corporation of
which he is such officer, and are not held by such corporation as a security
for any loan or as a collateral security for any payment or other purpose.

The tax commission is not required by this section to deduct amount of Baltimore
city stock held by a bank or other corporation from its assessment under secs. 166
and 166A, since that would exempt such stock from taxation, and thus create
inequality of taxation. System of corporate taxation in Maryland. Real estate
owned by a corporation is taxed as real estate owned by an individual—see secs. 166
and 166A. Remedy in case of an unlawful assessment by tax commissioner. When
tax commissioner is only a ministerial officer. Parties. Schley v. Lee, 106 Md. 394;

85