1096 ARTICLE 81.

tion, or because of any increase, reduction, abatement, modification, change
or alteration or failure or refusal to increase, reduce, abate, modify or
change any assessment, or because of any classification or change in classi-
fication, or refusal or failure to make a change, by the County Commis-
sioners, the Appeal Tax Court of Baltimore City or the assessing authori-
ties of any other city, may by petition appeal to the State Tax Commis-
sion therefrom, and the State Tax Commission shall hear and determine
all such appeals within sixty days from the entry thereof with said Com-
mission. Such appeal to the State Tax Commission shall be taken either
(a) within thirty days after the date of the action or failure or refusal
to act complained of, or (b) if an address shall have been filed with the
County Commissioners or the Appeal Tax Court by any person or corpora-
tion demanding a hearing as in the next preceding section provided, then
by the person giving such address within thirty days from the date of the
mailing of the notice of the action by the County Commissioners or the
Appeal Tax Court to the person and address so given. No appeal on be-
half of a taxpayer shall be allowed under this section from a failure or
refusal to abate, reduce or reclassify an existing assessment unless applica-
tion in writing for such action shall have been filed by the appellant with
the assessing authority appealed from within the time limited for the filing
of a demand for a hearing by Section 182 of this Article.

259. See notes to sec. 162.

See art. 5, secs. 90-1.

The valuation of property is not a judicial function, and the court cannot be
required to act as a board of review in the assessment of property, but is con-
fined to examination of legal principles upon which assessing board acted (de-
cision under sec. 253 of art. 81. 1024 Code). C. & P. Tel. Co. v. State Tax Com-
mission, 158 Md. 516.

Cited (as sec. 253, 1924 Code) but not construed in McLane v. State Tax
Commission, 156 Md. 135.

This section referred to in construing art. 101, sec. 56. Thomas v. Penna. R.
Co., 162 Md. 515.

1929, ch. 226, sec. 184.

184. A petition of appeal provided for in the last preceding section
shall set forth that the assessment or classification is illegal, specifying the
ground of alleged illegality, or is erroneous by reason of over-valuation or
under-valuation, or that the assessment is unequal in that it has been made
at a higher proportion of value than other property of the same class, or
said petition may assign any other errors which may exist in the particu-
lar case for which an appeal is allowed, and on account of which petitioner
claims to be injured. A summons, as well as a subpoena duces techum, ¹
shall issue from the State Tax Commission for the defendant named in such
appeal requiring it to produce at the hearing before the Commission the
record of its proceedings as well as all maps, plats, documents and other
papers connected with the record, and the record, or a copy of the record
when properly certified by the signatures of the assessing authority, shall

¹ Evidently a typographical error in act.