1098 ARTICLE 81.

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 there-
to, or in which the office of the Commission may be situated. Such appeals
shall be taken within thirty days from the date of the decision of the
Commission complained of, by petition setting forth the question or ques-
tions 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. There shall be a further right of appeal to the Court of
Appeals from any decision of the Circuit Court of the county, or the
Baltimore City Court of Baltimore City, as the case may be. Such appeals
must be taken within ten days of the final judgment or determination of
the lower Court; and the Court of Appeals shall immediately hear and
determine such appeal.

(b) Any taxpayer, any city, the County Commissioners of any county,
or the Attorney General on behalf of the State, claiming to be aggrieved
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 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.

Failure to take appeal within time prescribed, assessment becomes final and
binding (old sec. 259). Steam Packet Co. v. Baltimore, 161 Md. 9.

This section referred to in construing sec. 153. Tidewater Oil Co. v. Anne-
Arundel Co., Daily Record, April 8. 1935.