Appeal filing limits preserve the state's ability to contest similar tax issues despite administrative non-filing under directives. Commissioner-issued orders or instructions may fix monetary limits to regulate filing of appeals or applications by State tax officers; non-filing pursuant to those directives does not prevent filing in other cases on the same or similar issues, does not constitute acquiescence by the State tax officer, and appellate tribunals or courts must have regard to the circumstances under which the non-filing occurred.