TAX ADMINISTRATION 167

State Tax Commission to grant hearings and hear evidence
with respect to the valuations complained of and that, if the
alleged facts were found to be true, this body would have
taken action to remove the discriminations that formed the
basis for the suit. This decision was surprising, particularly
in view of the fact that in a previous case! involving similar
circumstances of alleged discrimination the Court had held
that it was “preposterous” and “unthinkable” that the
statutes conferred the power to decide such cases upon the
State Tax Commission. The Brinkerhoff-Faris case was
carried to the Supreme Court of the United States. In the
decision, rendered June 2, 1930, it was held that, while the
Supreme Court of Missouri “had the power to construe the
statute dealing with the State Tax Commission, and to
reexamine and overrule the Laclede case,” since the court
had not overruled its decision in the Laclede case until June
29, 1929, the time during which appeals could be made to
the State Tax Commission on account of valuations for taxes
of 1929 had expired. It was held further that at no time
“did the State provide to the plaintiff an administrative
remedy against the alleged illegal tax; and in invoking the
appropriate judicial remedy, the plaintiff did not omit to
comply with any existing condition precedent.” The judgment
 of the Supreme Court of Missouri in this particular case
was therefore reversed on the ground that no redress had been
possible.
At the present time the procedure in cases of complaint
concerning bank assessments is taken in accordance with the
decision of the Missouri Supreme Court in the Brinkerhoff-Faris
 case. The banks first appear before the county boards
of equalization and protest their assessments as discriminatory.
 Then, under the Brinkerhoff-Faris decision, an appeal
has to be taken to the State Tax Commission, and finally,
if the desired redress is not obtained through the Commission,
 action must be taken through the regular court proceedings.
 Unfortunately, this method does not establish any
principle that can be used in assessing banks generally
‘hroughout the state. The continued protests by the bankyf

 de Land and Improvement Company v. State Tax Commission, 295
Mo. 298.