2672 ARTICLE 81.

hundred dollars for county, city and municipal taxation in such county
or city of this State in which the owners may reside.

The act of 1896, ch. 143, withdraws all bonds, etc., issued by any corporation from
operation of system of assessment and taxation provided by act of 1896, ch. 120
(see sec. 218), and subjects them to a different mode of assessment and taxation,
leaving certificates of indebtedness issued by individuals or firms still subject to the
methods prescribed by latter act. The act of 1896, ch. 143, repealed act of 1896, ch.
120, quoad corporate bonds. This section construed in connection with sec. 224.
Object of this section. Mortgage bonds issued by a corporation being taxable under
this section to holders thereof in counties where they reside, sec. 198 (imposing
mortgage tax) is not applicable to them. Musgrove v. B. & O. R. R. Co., 111 Md.
635 (decided in 1909); Frederick County v. Frederick City, 88 Md. 658.

No greater tax than thirty cents on dollar can be levied on securities mentioned
in this section for county and municipal purposes; no town or city within limits of
county can impose any other or greater tax. The fund realised from tax of thirty
cents on securities of residents of Frederick city should be divided evenly between
that city and Frederick county. Relief in equity. Frederick County v. Frederick
City, 88 Md. 655.

Money on deposit with a trust company, whether a receipt is issued therefor
or not, is not taxable. Unvarying construction of a statute over a period of years.
See notes to sec. 2. Baltimore v. Machen, 132 Md. 620.

This section does not constitute an illegal discrimination against national banks
under sec. 5219 of Revised Statutes of United States, it not appearing that this
section in its practical operation resulted in relieving the capital of private banking
firms from equal taxation, and all domestic incorporated banks and trust companies
being taxed at same rate. National Bank of Baltimore v. Baltimore, 92 Fed. 239
(affirmed in 100 Fed. 24).

Under this section and secs. 2 and 98, mortgage bonds secured by property in this
state and owned by residents of Maryland are taxable to owners thereof and not
to corporation itself, nor is there any other provision of law imposing such taxation
upon corporation. Consolidated Gas Co. v. Baltimore, 101 Md. 556; Consolidated
Gas Co. v. Baltimore, 105 Md. 50.

This state has power to tax stocks, bonds and certificates of debt of other states
and of corporations created by them when held by residents of Maryland, although
such stocks, etc., are exempted from taxation by state issuing them or creating cor-
poration. Appeal Tax Court v. Gill, 50 Md. 396.

This section referred to in deciding that a seat on the Baltimore stock exchange
was not taxable. Baltimore v. Johnson, 96 Md. 745.

This section referred to in construing sec. 166—see notes thereto. Schley v.
Montgomery County, 106 Md. 410.

Cited but not construed in Baltimore v. State, 105 Md. 11.

See sec. 218, and notes.

An. Code, sec. 215. 1904, sec. 211. 1902, ch. 486, sec. 221.

226. All bonds, certificates of indebtedness or evidence of debt, in
whatsoever form, made or issued by any public or private corporation incor-
porated by this State or any other State, territory, district or foreign
country, or issued by any State, territory, district or foreign country, and
all personal property of any kind whatsoever, not exempt from taxation by
the laws of this State, in which any resident of any county of this State
has an equitable interest, with the legal title to the same in some other
person or corporation who is a resident of some other county of this State
or of the city of Baltimore, or (in the case of a corporation) which has its
main office or principal place of business in some other county in this State
or in the city of Baltimore shall be valued and assessed for the purposes
of state and county taxation to the equitable owner thereof in the county
in which he or she resides, to the extent of his or her equitable interest as
aforesaid, and the taxes due thereon shall be paid by the holder of said