REVENUE AND TAXES 3107

This section does not authorize county commissioners to appeal from action of state
tax commission, nor is there any appeal by county commissioners to state tax com-
mission. Cases reviewed. Nothing to show that county commissioners applied to state
tax commission to change or correct apportionment of assessment of corporate stock;
effect of appearance of attorney. State Tax Comn. v. Baltimore County, 138 Md. 672.

The fact that this section limits the appellate review to questions of law, referred
to in construing art. 23, sec. 113—see notes thereto. Industrial Corp. v. State Tax
Comn., 134 Md. 380.

This section referred to in Hyattsville v. C. & P. Tel. Co., 131 Md. 593.

An. Code, 1924, sec. 253. 1912, sec. 239. 1914, ch. 841, sec. 239. 1929, ch. 226, sec. 183.

191. Any taxpayer, any city, or the Attorney General on behalf of the
State, or a supervisor of assessments as provided in Section 184 ¹ of this
Article, claiming to be aggrieved because of any assessment or classifica-
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 190 of this Article.

This section applied by State Tax Commission in ordering abatement of assessment
on cemetery. Cemetery v. Baltimore Co., 174 Md. 284.

259. See notes to sec. 171.

See art. 5, secs. 91-92.

The valuation of property is not a judicial function, and the court cannot be re-
quired to act as a board of review in the assessment of property, but is confined to
examination of legal principles upon which assessing board acted (decision under sec.
253 of art. 81, 1924 Code). C. & P. Tel. Co. v. State Tax Commission, 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. 70. Thomas v. Penna. R. Co.,
162 Md. 515.

See notes to sec. 191.

1929, ch. 226, sec. 184.

192. 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

¹ Sec. 177 evidently intended.
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