1796                                      VETOES

The object of this article is to provide equality in taxation, and
to prevent, as far as possible, the burden of supporting the govern-
ment from falling upon some individuals, to the exclusion or exemp-
tion of others. Baltimore City v. Starr Church, 106 Md. 281.

The Constitution of Maryland and the Federal Constitution do
not prevent the creation of an exemption so long as it applies equally
to all in a class, Williams v. Mayor and City Council of Baltimore,
289 U.S. 36, and the Legislature can exempt certain classes of per-
sons or corporations from the payment of taxes upon certain species
of property where the discrimination is founded upon public policy
or a reasonable distinction, and does not amount to an arbitrary dis-
tinction, Mayor and City Council of Baltimore v. German-American
Fire Insurance Co., 132 Md. 380. The constitutional requirement,
however, is violated wherever particular persons or properties, se-
lected arbitrarily from a class on which the burden of taxation is
imposed, have been exempted therefrom. Williams v. Mayor and City
Council of Baltimore, supra; Baltimore City v. Starr Church, supra.

It is our opinion that House Bill 387 creates an exemption from
State taxation of gas and gas producing properties in one county and
such an exemption is not pursuant to any public policy, either enunci-
ated or implied, and is, therefore, discriminatory. Factually, the bill
would create a situation where taxpayers of gas and gas producing
properties in Allegany County are afforded favorable tax treatment
which would not be available to taxpayers in other counties of the
State. The converse of this situation existed in Casey Development
Corp. v. Montgomery County, 212 Md. 138, where the Court of
Appeals held unconstitutional a provision of the Montgomery County
Code which required improvements on land which became substan-
tially completed between July 1 and September 30 in each year to be
subject to taxation at ¾ of the regular rate levied that year for State
purposes. In striking down the provision as violative of Article 15
of the Declaration of Rights the Court said:

"..... the statute does not apply to the entire State; conse-
quently, if the improvements in Montgomery County that are
completed as above mentioned are taxed for State purposes and
similar improvements in the rest of the State are not, the tax
would fail to be uniform and would discriminate against the
property owners in Montgomery County."

The principle of uniformity stated in the Casey case is germane
here because the exemption from State taxation in House Bill 387
applies only to Allegany County.

Another constitutional objection to House Bill 387 is that there
is no mention in the title that this bill creates an exemption from all
other taxes. We believe that this omission violates Article III,
Section 29, of the Maryland Constitution which provides that ".....
every law ..... shall be described in its title." The purp