THEODORE R. MCKELDIN, GOVERNOR                    293

any person liable to pay the same to the State from and after the
time when notice has been given that such tax has become due and
payable as provided herein. Notice of such lien shall be filed by the
Comptroller with the clerk of the circuit court of the county in which
said property is located, or if located in Baltimore City, with the clerk
of the Superior Court of Baltimore City. Each clerk of court
shall accurately and promptly record and index all such notices of
lien filed with him by the Comptroller and shall enter such lien
in the judgment docket of the court, stating the name of the de-
linquent taxpayer, the amount of the lien and the date thereof. The
lien provided for in this section shall have the full force and effect
of a lien of judgment. Unless another date is specified by law, the
lien arising at the date of nonpayment as in this section specified and
provided for, shall continue with the same force and effect as a judg-
ment lien. ANY SUCH LIEN ON PERSONAL PROPERTY SHALL
NOT BE EFFECTIVE AS AGAINST AN INNOCENT PUR-
CHASER FOR VALUE UNLESS THE PERSONAL PROPERTY
HAS BEEN LEVIED UPON BY AN OFFICER OF A COURT.

352. Appeal from determination of Comptroller.

Any taxpaper dissatisfied with any final determination of the
Comptroller upon application for revision of any assessment or re-
fusal of refund, may, within [sixty (60)] thirty (30) days after
notice by the Comptroller of his determination, appeal from such
determination to the circuit court for the county in which the tax-
payer regularly conducts his business, or in the county in which the
transactions occurred upon which the assessment is based, or to the
Baltimore City Court if the taxpayer regularly conducts his business
in Baltimore City, or if the transactions on which the assessment is
based, occurred in Baltmioro BALTIMORE City. Such appeal shall
be limited to questions of law only, but the Comptroller shall file in the
court to which the appeal has been taken a certified copy of the record
of: proceedings held before him. Such appeals shall be taken by peti-
tion setting forth the question or questions of law which it is desired
by the appellant to review, and notice thereof shall be given by sum-
mons or subpoena, duly served on all parties directly in interest, by
the sheriff of the county or city in which said appeal is filed. If the
taxpayer, or the Attorney General on behalf of the State, or the Comp-
troller are dissatisfied with the determination of the circuit courts
for the counties or the Baltimore City Court, as the case may be, they
or either of them may appeal to the Court of Appeals of Maryland.

368. How notice given.

Any notice authorized or required under the provisions of this sub-
title may be given by mailing the same to the person for whom it is
intended in a postpaid envelope addressed to such person at the ad-
dress given in his last return filed by him or in any application made
by him pursuant to the provisions of this subtitle. If no return has
been filed or no application made, notice may be given by mailing the
same to such address of the person for whom it is intended as may be
obtainable. The mailing of such notice shall be presumptive evidence
of the receipt of the same by the person to whom it is addressed. Any
period of time which is determined according to the provisions of
this subtitle by the giving of notice shall commence to run from the
date of mailing of such notice.