536 ARTICLE 81.

be deemed to be, the investigation, inquiry and hearing of the Commission;
provided, that each and all decisions of a Commissioner shall not become

effective until approved by the Commission itself. The determination of
any matter brought before the Commission shall be evidenced by a judg-
ment or order duly signed by at least two of its members and filed with its
Secretary. A copy thereof, duly certified by said Secretary, under the

seal of the State Tax Commission, shall be evidence in any cause or pro-
ceeding in any court of this State.

256. Where taxpayer is notified by S. T. C. of proposed assessment and fails
to protest or take appeal, he may not attack assessment in suit by city for taxes.
Notice reasonable. Whether personal property is used entirely or chiefly in con-
nection with manufacturing under act 1918, ch. 82, is question of fact. Appeal
from S. T. C. on questions of law only. Can-oil County v. Shriver Co.. 146 Md.
412, distinguished. Schluderberg, etc.. v. Baltimore, 151 Md. 609.

1929, ch. 226. sec. 163.

163. The Commission shall have power to provide for a system of hear-
ings on petitions of appeal filed with it adopting such reasonable rules of
procedure relating to taking testimony and argument thereon, as it shall
deem proper. It shall adopt such regulations regarding notices of assess-
ments made by it and hearings thereon as it may deem proper.

1929, ch. 226, sec. 164.

164. The Attorney General shall be the legal adviser and representative

-of the Commission and shall deliver opinions to said Commission on the
request of a majority of said Commission, or of the Chairman thereof.

1929, ch. 226, sec. 165.

165. The Commission, or any member thereof, or the Secretary, shall
have power to issue summons for witnesses to appear before said Commis-

sion, the same to be served by the sheriff or his deputy of the jurisdiction
where the person to be summoned is found, or may be served by any em-
ployee of said Commission. If a person summoned to attend before the
Commission or a Commissioner fails to obey the command, without reason-
able cause, or if a person in attendance before the Commission or a Com-
missioner shall, without reasonable cause, refuse to be sworn or examined,
or answer a question, or produce a book or paper when ordered to do so
pursuant to summons, the Commission or Commissioner may apply to any
Judge of the Supreme Bench of Baltimore City or of the Circuit Court
of any county, upon proof by affidavit of the fact, for a rule or order return-
able within not less than two nor more than five days, directing such person
to show cause before the Judge who made the order, or any other Judge
of the same Circuit, why he should not be adjudged guilty as of a contempt
and punished as contempts are punishable by courts of record. Upon the
return of such an order, the judge, before whom the matter shall come on
for hearing, shall examine under oath such person, with full opportunity
to such person to be heard in his own defense. If the judge shall determine
that such person has no reasonable cause or legal excuse to refuse to be

See important footnote on first page of this article.