REVENUE AND TAXES 3109

the decisions of the State Tax Commission, in the exercise of its appellate
jurisdiction, on questions of law only, to the Circuit Court of any county
or the Baltimore City Court of Baltimore City, in which the property or
any part of the property the assessment of which is involved may be situ-
ated, or in which the taxpayer may reside or be taxable in respect thereto,
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.

Order of State Tax Commission abating assessment on cemetery reversed by Court
on appeal. Cemetery v. Baltimore Co., 174 Md. 284.

Cited in the matter of the appeal of the Fidelity Trust Co. from the action of the
State Tax Commission. (Judge Smith, Circuit Court of Baltimore City), Daily Record,
June 16, 1939.

Cited in construing sec. 2 (8) and (9). Tax Comm. v. Allied Mortgage Cos., 175
Md. 357.

Cited in Canton Nat. Bank v. Tax Comm. (Judge Adams, Circuit Court No. 2 of
Baltimore City), Daily Record, Nov. 17, 1939; Tar Products Corp. v. Tax Comm.,
176 Md. 293.