REVENUE AND TAXES. 2673

legal title to the collector of taxes for the county or city in which said
property is so valued and assessed. All provisions of this section, when
they shall become operative, shall repeal all laws or parts of laws, incon-
sistent herewith, to the extent of such inconsistency.

The 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 not taxable under this section, but
under sec. 2. This section does not prescribe a different measure or method of
valuation and assessment from sec. 2. The property from which an equitable interest
springs rather than the 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.

Where stock belonging to residents of Maryland is held under a voting trust, it is
taxable to such shareholders rather than to voting trustees. State Tax Comn. v.
Baltimore County, 138 Md. 677.

This section is constitutional and valid, it being in pari materia with laws requir-
ing corporations to pay taxes on their stock for shareholders; two laws should be con-
strued together and residence of cestui que trust treated as situs for taxation. Cases
distinguished. The question of a conflict between this section and art. 3, sec. 51, of
state Constitution, and of whether this section was intended to apply to interests in
lands, not passed on. Baltimore v. Safe Deposit Co., 97 Md. 660. And see Baltimore
v. Allegany County, 99 Md. 9; State Tax Commission v. Baltimore County, 138
Md. 677.

As to the taxation of personal property in which a resident of Maryland has an
equitable interest, the legal title being in a non-resident, see sec. 2.

An. Code, sec. 216. 1904, sec. 212. 1888, sec. 155. 1896, ch. 120, sec. 2. 1896, ch. 143, sec. 202.

227. No extra assessment shall be made, and no extra or special tax
shall be levied or collected on any bridge or bridges over streams or any
tunnel forming any part of the roadway of any railroad or railroads or
turnpike in this State, it being the meaning and intent of this section
that any bridge over streams or any tunnel forming a portion of the road-
way of any of said railroads or turnpikes shall be valued and assessed at
the same rate that any other equal portion of such railroad or turnpike is
valued.

See art. 23, sec. 250.

An. Code, sec. 217. 1904, sec. 213. 1898, ch. 286, sec. 203.

228. All shares of stock in any bank (other than a national bank)
incorporated by or located in or doing business in this State shall be
valued and assessed for the purpose of State, county and municipal tax-
ation to the owners thereof in the county or city in this State, in which
said owners may respectively reside, in the same manner and to all in-
tents and purposes as if the said shares of stock were shares of stock in a
national bank located in this State, to the end that at no time shall the
shares of stock in any bank incorporated by or located in or doing busi-
ness in this State (other than a national bank) or the owner or owners
thereof be liable for or subject to any other or greater taxation than the
same, or the owner or owners thereof, would be if the said shares of stock
were shares of stock in a national bank located in this State.
See secs. 2 and 166 and 166A, and notes.
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