Mayor of Baltimore v. Harper

Bomt>, O. J.,

delivered the opinion of the Court.

The question presented on this appeal is whether a “mortgage participation certificate,” issued by a corporation mortgagee, distributing to subscribers, rights and interests under a single, specified mortgage, is taxable in the hands of a holder of the certificate, under article 81, section 214 of the Maryland Code, providing for taxation of “bonds, certificates of indebtedness and evidences of debt * * * of any corporation not exempt from taxation by the laws of this State.” The lower court, reversing the State Tax Commission, held that such a…