REVENUE AND TAXES. 2687

appeals to the Circuit Courts in the several Counties of the State, shall
continue in force so far as the same are applicable and not inconsistent with
the other provisions of this sub-title, except only that the State Tax Com-
mission shall be substituted for, and exercise the functions now exercised
under said Acts by said Baltimore City Court and the Circuit Courts of
the several counties, respectively. Appeals from any action of the State
Tax Commission to court, as authorized by Section 253 hereof, shall be
taken within thirty days of such action by petition setting forth the question
or questions of law which it is desired by the appellant to review, and
notice thereof shall be given by summons or subpoena, duly served on all
parties directly in interest, by the Sheriff of the county or city in which
said appeal is filed, and shall be heard and decided by the court, sitting
without a jury. All appeals to court in Baltimore City shall be to the Balti-
more City Court, and there shall be a further right of appeal to the Court
of Appeals from any decision of the Baltimore City Court or of the circuit
courts of the several counties. Such appeals must be taken within ten days
of the final judgment or determination of the lower court. The power
to assess shall in all cases include the power to classify for taxation, and
the power to review an assessment on appeal shall in all cases include also
the power to review any question of classification for taxation.

The state tax commission has jurisdiction to entertain an appeal from appeal tax
court. An appeal lies from state tax commission on questions of law only. The
valuation of property for taxation is not a judicial function, and court of appeals
may not be required to act as a board of review in assessment of property. Proceed-
ings of public service commission in rate case properly admitted in evidence. Prayers!
Evidence. Procedure. Baltimore v. C. & P. Tel. Co., 131 Md. 54-55; Postal Tel. Co.
v. Harford County, 131 Md. 100; Fidelity Trust Co. v. Gorman, 134 Md. 338.

Meaning of this section made clear. Telephone company held to have right to
apply to state tax commission for relief from an assessment imposed by a municipal-
ity; commission had the right to act on such application. On appeals from the
state tax commission, the courts only pass on .questions of law. Art. 81, sec. 19A
(An. Code of 1912) was repealed by act of 1914, ch. 841 (sec. 247, et seq.). The
commission has jurisdiction to review assessments made by cities, towns and villages
other than Baltimore city. Hyattsville v. C. & P. Tel. Co., 131 Md. 592.
See notes to secs. 2, 24, 249 and 253.

An. Code, sec. 246. 1914, ch. 841, sec. 2.

260. The office of State Tax Commissioner is hereby abolished im-
mediately upon the qualification of the Commission hereby created and all
the duties imposed upon or powers given by existing law (or by any Act
or resolution passed at the present session of the Legislature) to the State
Tax Commissioner shall devolve upon the State Tax Commission; and
wherever any duties are imposed by existing law (or by any Act or resolu-
tion passed at the present session of the Legislature) upon persons or
corporations to make report to the State Tax Commissioner or to perform
any other act or thing in respect to his office, such duties, reports, acts
and things shall be made and performed to the State Tax Commission.
Wherever the State Tax Commissioner, by virtue of his office, is a member
of any board, committee or other similar body, the chairman of the State
Tax Commission shall hereafter serve in his place, provided that said
repeal shall in no way affect the validity of any action taken by the State
Tax Commissioner before May 29, 1914.

This section referred to—see notes to secs. 2, 249 and 259. Hyattsville v. C. & P
Tel. Co., 131 Md. 596.