570                                  Laws of Maryland                         [Ch. 399

mission on which its finding was based. Either side may introduce
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, unreason-
able or against the substantial weight of the evidence. If the Court
finds such error it shall remand the case to the Commission for fur-
ther proceedings in accordance with its opinion or order; otherwise
the action of the Commission shall be affirmed. From the final deci-
sion 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 thirty 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.

348. Any taxpayer dissatisfied with any final determination of
the Comptroller upon application for revision of any assessment or
refusal of refund, may, within sixty days (60) days after notice by
the Comptroller of his determination, appeal from such determina-
tion to the circuit court for the county in which the taxpayer regu-
larly 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 Balti-
more City, or if the transactions on which the assessment is based
occurred in 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 petition setting forth
the question or questions 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. If the taxpayer, or the
Attorney General on behalf of the State, or the Comptroller are dis-
satisfied 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 [within thirty (30) days from the final order entered by
such court] appeal to the Court of Appeals of Maryland [, and the
Court of Appeals shall immediately hear and determine such appeal].

Sec. 35. And be it further enacted by the General Assembly of
Maryland, That Section 147 of Article 83 of the Annotated Code of
Maryland (1951 Edition), title "Sales and Notices", sub-title "Finance
Companies and Investigations", be and it is hereby repealed and
re-enacted, with amendments, to read as follows:

147. (Court Review.) Any person aggrieved by a refusal, sus-
pension or revocation of license by the Commissioner, may appeal,
within thirty (30) days after notice of such action, to the Circuit
Court for the county where the business was or was to be carried
on, or to any common law court in Baltimore City. The case shall be
tried de novo and the court may reverse, affirm or modify the order
of the Commissioner. Such appeal shall operate to suspend the order
appealed from pending the hearing on the merits, until the Court
orders otherwise.