(after stating the facts). The judgment of the chancery court was correct. At the outset it may be stated that the act of the county authorities in doubling the assessed value of the property of the railroad company for county purposes under the circumstances" was a mere clerical act, and that the real raising of the taxes was done by the Arkansas Tax Commission. The record shows that the Arkansas Tax Commission had assessed the property of the railroad company on a basis of 50 per cent, of its value, just as it had assessed the value of all other railroads in Arkansas. Under the judgment of the federal court, it was ordered to assess the property of the defendant railway company in Cleveland County for county purposes only at its full value. Hence the direction" of the Arkansas Tax' Commission to the local authorities to multiply the taxes as already extended against the property of the railway company and the compliance with the order by the local authorities amounts in'fact to an assessment by the Arkansas Tax Commission of the property of the railway company at its full value for county purposes only. This action was in direct 'violation of the principles of' law decided in Hays v. Missouri Pacific Railroad Co., 159 Ark. 101, and State ex rel. Craighead County v. St. Louis-San Francisco Railway Co., 162 Ark. 443.

In those oases it was held that under our Constitution all property shall be taxed according to its value to be ascertained as the General Assembly shall direct, making the same equal and uniform throughout the State.

In the case last cited it was expressly held that a judgment of a federal court directing an assessment of all property in a county at its full valuation contemplates an assessment for all purposes, and that an assessment of property at its full valuation for county purposes only is invalid.

In that case the court further held that taxpayers are not bound by an illegal assessment, though the effect is merely to relieve them from part of the assessment which otherwise would be imposed.

. In the case at bar the letter of the Arkansas Tax Commission shows on its face that the judgment of the federal court directed it to assess for county purposes only all assessments of property made by it in Cleveland County for the year 1922, and it undertook to raise the assessment in compliance with the order of the federal court, for county purposes only. As we have just seen, this violated the uniformity clause of our Constitution and rendered the tax to that extent void.

The order by the Arkansas Tax Commission to the county assessing authorities of Cleveland County for the year 1921 was ..lost, but the oral proof shows that it was the same as that for the year 1922. Hence the raise, having been made for county purposes only, was illegal and void as being in violation of the uniformity clause of our Constitution with regard to taxation, and for that reason the chancery court also properly enjoined the sheriff and collector from, collecting the excess taxes for that year.

It is also sought to uphold the decree under the judgment of the federal court of March 28, 1923, which set aside and revoked the mandamus issued on the 21st dlay of April, 1921. This order was made 'by -the federal court upon the application of J. H. Meek, who had become the owner of the judgment against Cleveland 'County for the collection of which the mandamus was issued in the first place- This order shows on its face that it is only intended to operate prospectively and has no bearing whatever on the proceedings in this case Which had been had before the díate of the order revoking the mandamus.

The result of our views is that the decree of the chancery court was correct in each case, and it will therefore be affirmed.