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<h1>Monetary limits on state tax appeals restrict filings administratively but do not amount to acquiescence; courts must consider context.</h1> Commissioner may, on Council recommendations, prescribe monetary limits by order or instruction to regulate filing of appeals by State tax officers; such limits do not bar filing in other cases with similar issues and non-filing under those directions is not to be construed as acquiescence, with tribunals and courts required to have regard to the circumstances of non-filing.