RODMAN, Justice.
The Machinery Act, G.S. § 105-271 et seq., prescribes the time and manner for listing and valuing property for ad valorem tax purposes. It also fixes the time for payment. The portions of the act pertinent to a decision of this case provide:
Property must be listed annually, G.S. § 105-280. Personal property is valued annually, G.S. § 105-280; real property is valued octennially, G.S. § 105-278. The values are as of January...
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