ALBERT C. RITCHIE, GOVERNOR. 707

by the State Tax Commission, in the exercise of its original
jurisdiction, in assessing or refusing to assess or in re-assess-
ing or refusing to re-assess, classify or refusing to classify,
any property or computing any tax, or in increasing, re-
ducing or abating any assessment, may appeal to the Cir-
cuit 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, in-
cluding a statement of all facts considered by said Commis-
sion on which its finding was based. Either side may intro-
duce additional testimony or other evidence in the Circuit
Court. Such petition of appeal shall set forth concisely the
particulars in which the action of the Commission is claimed
to be unlawful, unreasonable or against the substantial weight
of the evidence. If the Court finds such error it shall remand
the case to the Commission for further proceedings in accord-
ance 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 sec-
tion 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 imme-
diately 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.

187. The appeal from the State Tax Commission pro-
vided for in the last preceding section shall be taken within
fifteen days from the date of the order, action or refusal to
act of the State Tax Commission, or if an address shall have
been filed as hereinabove provided, then within fifteen days
after the mailing, postage prepaid, of a copy of such order,
action or refusal to act, to such address.

188. No appeal to the State Tax Commission from the
County Commissioners or the Appeal Tax Court, and no
appeal from the State Tax Commission to a Circuit Court,