BALTIMORE CITY. 977

1896, ch. 322. 1908, ch. 167.

170. Any person or persons, or corporation, assessed for real or per-
sonal property in the City of Baltimore and claiming to be aggrieved be-
cause of any assessment, or classification made by the said Court, or be-
cause of its failure to reduce or abate, modify, change or alter any exist-
ing assessment or classification may, by petition, appeal to the State Tax
Commission to review the assessment or classification. The Mayor and
City Council of Baltimore may also appeal from any decision of said
Court to the State Tax Commission if it deem the public interests re-
quire that the decision of said Court should be reviewed. The petition
in such appeal, other than the petition of the city, shall set forth that the
assessment or classification is illegal, specifying the grounds of the alleged
illegality, or is erroneous by reason of overvaluation, or other error; or
that the assessment is unequal in that the said assessment has been made
by a higher proportion of valuation than other real or personal property
on the same tax roll, by the same officer; and that the petitioner is, or will
be injured by such alleged illegality, inequality or erroneous assessment
or classification. The petition of the Mayor and City Council of Balti-
more shall set forth wherein the decision of said Court is erroneous and
such other facts as may be necessary to inform the State Tax Commission
of the claim of the city. A summons shall issue for the respondent or
respondents named in the petition of the city returnable on such a day
as the State Tax Commission may appoint for a hearing of the matter
averred in such petition. All such appeals shall be taken within thirty
days after an assessment, or classification, has been made as aforesaid,
or within thirty days after the refusal to reduce or abate, modify, alter or
change an existing assessment, or classification, or within thirty days after
the action of said Court complained of by the city. On such appeals
the State Tax Commission shall appoint a day for hearing said appeals,
which shall not be less than five nor more than thirty days after the expi-
ration of the thirty days' limit for taking appeals as aforesaid; and shall
direct its clerk to issue a subpoena duces tecum to the judges of said
Appeal Tax Court, requiring them to produce and deliver to said Com-
mission the record of the proceedings of the said Appeal Tax Court, and
all maps, plats, documents and other papers connected with the said
record; the said Commission shall have full power to hear and fully
examine the subject and decide on said appeals, and for that purpose it
is hereby authorized and empowered to adjourn from time to time, and
may cause all or any such appeals to be consolidated, or may hear and
decide them separately, and may require the said judges of the Appeal
Tax Court, their clerks, surveyors or other agents and servants, or any of
them, and all such other persons as the Commission may deem necessary
to attend, and examine them on oath or affirmation; and may permit and
require all such explanation, amendments and additions to be made to
and of the proceedings as the Commission shall deem requisite. The
Commission shall hear all appeals de novo, and shall ascertain and decide