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Pz! <br />-5- <br />listing period, because his unlisted property was never included <br />in the county's tax base. Granting an exemption to unlisted <br />property would not jeopardize the budget adopted by the county. <br />Taxpayer's remaining assignment of error involves the <br />constitutional validity of the Commission's interpretation of <br />G.S. 105- 282.1. Since this issue was not raised before the Board <br />of Equalization and Review and since the one issue before the <br />Property Tax Commission did not include constitutional questions, <br />Taxpayer cannot raise the issue on appeal to this Court. See <br />White v. Pate, 308 N.C. 759, 309 S.E. 2d 199 (1983). <br />The decision of the North Carolina Property Tax <br />Commission is <br />Affirmed. <br />Judges WELLS and BRASWELL concur. <br />A TRUE COPY <br />URT OF APPEALS <br />CLERK OF TH RTNO CAR IN <br />OF / <br />SY. EPUTY GEERK 7 <br />a2 d • j9 <br />