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21 <br />-t- <br />issue: whether a tax supervisor or board of equalization and <br />review has authority to grant an exemption for property which its <br />owner had listed during the listing period but failed to file an <br />application for exemption during this period. After considering <br />the evidence of the parties and the law governing the taxation of <br />property set out in the "Machinery Act," G.S. 105 -271 et seq., <br />the Commission concluded: <br />There is no authority, under the Machinery <br />Act as presently written, for either the tax <br />supervisor or the board of equalization and <br />review to grant an exemption for property <br />which its owner had listed during the listing <br />period but for which its owner failed to file <br />an application for exemption during the <br />listing period. <br />From this final decision of the Commission, Taxpayer appeals, <br />Thomas & Coltrane, by Raymond D. Thomas, for appellant <br />Wesleyan Education Center. <br />P. Eugene Price, Jr. and Jonathan V. Maxwell, for <br />appellee Forsyth County. <br />ARNOLD, Judge. <br />Taxpayer assigns error to the Commission's decision and <br />argues that the Machinery Act presently allows either a county <br />tax supervisor or board of equalization and review to grant an <br />exemption when the owner has listed his property during the <br />listing period but does not apply for exempt status until after <br />this period. We disagree for the reasons given in the <br />Commission's decision. <br />