REVENUE AND TAXES. 547

because of any final action taken by the State Tax Commission, in the
exercise of its original jurisdiction, in assessing or refusing to assess or in
re-assessing or refusing to re-assess, classify or refusing to classify, any
property or computing any tax, or in increasing, reducing or abating any
assessment, may appeal to the Circuit Court of any county sitting in
equity, or the Circuit Court or Circuit Court No. 2 of Baltimore City, in
which the property or any part of the property the assessment of which is.
involved may be situated, or in which the taxpayer may reside or be taxable
in respect thereto, or in which the office of the Commission may be situated,
All such appeals shall be upon the record of proceedings before the State
Tax 'Commission certified to the Court by said Commission, including a
statement of all facts considered by said Commission, on which its finding
was based. Either side may introduce additional testimony or other evi-
dence in the Circuit Court. Such petition of appeal shall set forth con-
cisely the particulars in which the action of the Commission is claimed
to be unlawful, unreasonable or against the substantial weight of the evi-
dence. If the Court finds such error it shall remand the case to the Com-
mission for further proceedings in accordance with its opinion or order;
otherwise the action of the Commission shall be affirmed. From the final
decision of the Court hearing such appeal any party named in this section
may take an appeal to the Court of Appeals in the same manner as in other
equity cases, but within ten days after the order appealed from; and the
Court of Appeals shall immediately hear and determine such appeal.

(c) The power of the State Tax Commission to assess shall in all eases
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.
See art. 5, secs. 90-1.

1929, ch. 226. sec. 187.

187. The appeal from the State Tax Commission provided for in the
last preceding section shall be taken within fifteen days from the date of
the order, action or refusal to act of the State Tax Commission, or if an
address shall have been filed as hereinabove provided, then within fifteen,
days after the mailing, postage prepaid, of a copy of such order, action or
refusal to act, to such address.

1929, ch. 226, sec. 188.

188. No appeal to the State Tax Commission from the County Com-
missioners or the Appeal Tax Court, and no appeal from the State Tax
Commission to a Circuit Court, or from a Circuit Court to the Court of
Appeals, shall stay or in any manner affect the collection or enforcement of
the assessment or classification complained of; but upon the final deter-
mination of any such appeal any taxes which such determination may show
to have been illegally collected, shall be to the extent of illegality forthwith
refunded with interest, and the disbursing officers of the State and of the