166 THE FISCAL PROBLEM IN MISSOURI 
909% of full value, the action of the County Board of Equali- 
zation in denying relief, and the action of the State Board of 
Equalization in raising the value of the shares to 100%, of 
their true value in money, leaving other forms of property on 
a 759% basis, represented “a deliberate, systematic, inten- 
tional, and arbitrary discrimination against the plaintiff and 
its shareholders” and that it was therefore in direct violation 
of the uniformity and according-to-value provisions of the 
constitution of Missouri and of the equal protection provi- 
sion of the Federal Constitution. In this case relief had been 
sought in a bill of equity, and the Supreme Court of Missouri 
was called upon to decide whether the taxpayer had invoked 
the appropriate remedy. The court held that the appro- 
priate remedy had been pursued, and that the taxpayer was 
entitled to relief, if the alleged facts were proved. In the 
light of a more recent decision, it is interesting that no men- 
tion was made of appeal to the State Tax Commission as a 
source of relief. The decision in the Boonville case concluded 
with the following emphatic statement: 
“There is no reason why bank stock should be assessed at 
its full value and all other property at 75% of its full value. 
Such an action is not only a fraud upon the taxpayers who 
are thus assessed the full value of their property, but it is 
a violation of the uniformity and due process clauses of our 
State Constitution, as well as a violation of the 14th Amend- 
ment to the Federal Constitution. The substantial citizens 
of Missouri do not want and have not asked for this unjust 
discrimination as between the taxpayers of the State. Let 
even-handed justice be done to all taxpayers.” 
In the Brinkerhoff-Faris case, decided some time after the 
Boonville case, the Supreme Court of Missouri held, on 
appeal, that relief from the alleged discriminatory assessment 
could not be had in any suit at law, and that the bill in equity 
was the appropriate and only remedy, unless relief could 
have been had by timely application to some administrative 
board, and that neither of the boards of equalization was 
charged with the power to grant such relief! The Court 
held. however. that it was within the jurisdiction of the 
1 BY achat Furs Trust and Savings Company v. Hill, Treasurer, etc., 19 S. W. 
2d