Kavanagh, C. J.
I.
Plaintiffs urge that these cases be remanded to the Tax Tribunal for proceedings to challenge the State Tax Commission’s intercounty equalization determination. Defendant, however, contends that the Tax Tribunal has no reviewing authority over intercounty equalization.
On July 1, 1974 the Tax Tribunal was established pursuant to provisions of the Tax Tribunal Act, 1973 PA 186; MCLA 205.701 et seq.; MSA 7.650(1) et seq. Section 31 of the Tax Tribunal Act, MCLA 205.731; MSA 7.650(31), confers upon the tribunal the exclusive and original jurisdiction to review assessment, valuation, rates, special assess[554]*554ments, allocation disputes, and, inter alia, equalization, under property tax laws. Section 41 of the same act, MCLA 205.741; MSA 7.650(41), endows the tribunal with jurisdiction over actions which were heretofore reviewable by the State Tax Commission or by a circuit court. Section 31 and § 41 of the Tax Tribunal Act transfer the tax commission’s former appellate jurisdiction over county equalization appeals to the Tax Tribunal. Clearly, appeals from intracounty equalization by Boards of Commissioners were formerly reviewable by the State Tax Commission and can and will be reviewed by the Tax Tribunal. Cooper Township v State Tax Commission, 393 Mich 58; 222 NW2d 900 (1974).
Intracounty equalization appeals satisfy the conditions of both § 31 and § 41 of the Tax Tribunal Act, i.e., they are equalization matters arising under the property tax laws and they are matters formerly appealable to the State Tax Commission.
However, it is equally clear that the Tax Tribunal Act does not contemplate nor authorize the tribunal to assume jurisdiction over state equalization.
The laws of this state, since 1913 PA 201, have provided an appeal of intracounty equalization to a state body (the Board of State Tax Commissioners, which was the progenitor of the State Tax Commission), whereas there never has been any provision for administrative review of state equalization of the 83 counties. Also, the Legislature provided by 1972 PA 296 for a tentative levy of taxes during the pendency of a county equalization appeal before the Tax Commission, with a final levy subsequent to resolution of the appeal, whereas it never has enacted legislation dealing with the levy of ad valorem taxes during the time of controversion of state equalized values.
[555]*555These actions of the Legislature deliberately retain the clear distinction between county equalization and state equalization. They also reveal legislative recognition of the need for review of intracounty equalization and the concomitant need for precluding administrative review of state equalization.
In § 41 of the Tax Tribunal Act, the Legislature made it clear that it was vesting jurisdiction in the Tax Tribunal over matters previously heard by the State Tax Commission as an appellate body. Formerly, the State Tax Commission was the appellate body over individual assessments, allocation disputes and intracounty equalization matters. The State Tax Commission did not act as an appellate body over state equalization. Section 41 does not limit the jurisdiction of the tribunal as conferred by § 31, but is in fact entirely consistent with § 31. Section 31 places jurisdiction in the Tax Tribunal over those matters arising under the property tax laws and, consistent therewith, § 41 eliminates the tax commission and the circuit court as forums in which those very matters were formerly litigated. In the context of this case, § 31 gives the Tax Tribunal jurisdiction over county equalization appeals and § 41 eliminates the tax commission as the forum for its review. The "equalization” subject to the Tax Tribunal’s jurisdiction is the very same equalization that historically and statutorily had been reviewed by the State Tax Commission. The Tax Tribunal succeeded to that jurisdiction as it succeeded to the other appellate jurisdictions of the tax commission.
In short, the Tax Tribunal ,now stands in the stead of the tax commission as a reviewing body; it has not become the reviewer of tax commission action in intercounty equalization.
[556]*556If a county believes itself aggrieved by the determination of the State Tax Commission concerning intercounty equalization, it may seek judicial review asserting fraud or error of law.
II.
The provisions of the Administrative Procedures Act, MCLA 24.201 et seq.; MSA 3.560(101) et seq. (APA), do not apply to intercounty equalization proceedings before the State Tax Commission.
Plaintiffs and the minority opinion herein rely on this Court’s recent opinion in Cooper Township v State Tax Commission, 393 Mich 58; 222 NW2d 900 (1974), as authority for requiring the State Tax Commission to operate in accordance with thv APA provisions.
Cooper Township, supra, and Ann Arbor Township v State Tax Commission, 393 Mich 682; 227 NW2d 784 (1975), both dealt with intracounty equalization. What we deal with in the instant case is intercounty equalization, a very different situation. The intercounty equalization process is replete with statutory deadlines, among which are the following:
(a) MCLA 211.34; MSA 7.52 requires that the county commissioners equalize their respective counties during the April session.
(b) MCLA 209.5; MSA 7.605 orders the county commissioners to forward their tabular statements (equalization reports) to the State Tax Commission by the first Monday in May.
(c) MCLA 209.2; MSA 7.602 orders the State Board of Equalization to convene on the second Monday in May to equalize assessments.
(d) MCLA 209.4; MSA 7.604, requires the board to prepare a tabular statement showing, by coun[557]*557ties, the total assessed valuation, the valuation as equalized by the commissioners, the previous year’s state equalized valuation, and current year’s recommended values. These figures must be forwarded to the county clerks. In addition to providing for the tabular statement described above, it provides for the State Board of Equalization to remain in session and finally conclude state equalization on the fourth Monday in May. Representatives of the several counties are heard on the fourth Monday in May, at which time the board determines the relative valuation of the 83 counties and adds to or deducts from the assessed values presented to it a sum which produces 50% of true cash value.
Despite these limitations, plaintiffs assert, and the minority opinion agrees, that state equalization must be conducted pursuant to the requirements of the Administrative Procedures Act which would conceivably require introduction into evidence of approximately 162,492 pages of record for 1974, and 70,000 pages for 1973, allow for the cross-examination of approximately 75 employees of the State Tax Commission, and allow counsel for 83 counties to submit and resubmit proposed findings of fact and conclusions of law. Presumably, the State Tax Commission, the adversary party according to plaintiffs, would have a right to review the evidence of the 83 counties, and cross-examine the county commissioners, or the equalization director of each county.
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Kavanagh, C. J.
I.
Plaintiffs urge that these cases be remanded to the Tax Tribunal for proceedings to challenge the State Tax Commission’s intercounty equalization determination. Defendant, however, contends that the Tax Tribunal has no reviewing authority over intercounty equalization.
On July 1, 1974 the Tax Tribunal was established pursuant to provisions of the Tax Tribunal Act, 1973 PA 186; MCLA 205.701 et seq.; MSA 7.650(1) et seq. Section 31 of the Tax Tribunal Act, MCLA 205.731; MSA 7.650(31), confers upon the tribunal the exclusive and original jurisdiction to review assessment, valuation, rates, special assess[554]*554ments, allocation disputes, and, inter alia, equalization, under property tax laws. Section 41 of the same act, MCLA 205.741; MSA 7.650(41), endows the tribunal with jurisdiction over actions which were heretofore reviewable by the State Tax Commission or by a circuit court. Section 31 and § 41 of the Tax Tribunal Act transfer the tax commission’s former appellate jurisdiction over county equalization appeals to the Tax Tribunal. Clearly, appeals from intracounty equalization by Boards of Commissioners were formerly reviewable by the State Tax Commission and can and will be reviewed by the Tax Tribunal. Cooper Township v State Tax Commission, 393 Mich 58; 222 NW2d 900 (1974).
Intracounty equalization appeals satisfy the conditions of both § 31 and § 41 of the Tax Tribunal Act, i.e., they are equalization matters arising under the property tax laws and they are matters formerly appealable to the State Tax Commission.
However, it is equally clear that the Tax Tribunal Act does not contemplate nor authorize the tribunal to assume jurisdiction over state equalization.
The laws of this state, since 1913 PA 201, have provided an appeal of intracounty equalization to a state body (the Board of State Tax Commissioners, which was the progenitor of the State Tax Commission), whereas there never has been any provision for administrative review of state equalization of the 83 counties. Also, the Legislature provided by 1972 PA 296 for a tentative levy of taxes during the pendency of a county equalization appeal before the Tax Commission, with a final levy subsequent to resolution of the appeal, whereas it never has enacted legislation dealing with the levy of ad valorem taxes during the time of controversion of state equalized values.
[555]*555These actions of the Legislature deliberately retain the clear distinction between county equalization and state equalization. They also reveal legislative recognition of the need for review of intracounty equalization and the concomitant need for precluding administrative review of state equalization.
In § 41 of the Tax Tribunal Act, the Legislature made it clear that it was vesting jurisdiction in the Tax Tribunal over matters previously heard by the State Tax Commission as an appellate body. Formerly, the State Tax Commission was the appellate body over individual assessments, allocation disputes and intracounty equalization matters. The State Tax Commission did not act as an appellate body over state equalization. Section 41 does not limit the jurisdiction of the tribunal as conferred by § 31, but is in fact entirely consistent with § 31. Section 31 places jurisdiction in the Tax Tribunal over those matters arising under the property tax laws and, consistent therewith, § 41 eliminates the tax commission and the circuit court as forums in which those very matters were formerly litigated. In the context of this case, § 31 gives the Tax Tribunal jurisdiction over county equalization appeals and § 41 eliminates the tax commission as the forum for its review. The "equalization” subject to the Tax Tribunal’s jurisdiction is the very same equalization that historically and statutorily had been reviewed by the State Tax Commission. The Tax Tribunal succeeded to that jurisdiction as it succeeded to the other appellate jurisdictions of the tax commission.
In short, the Tax Tribunal ,now stands in the stead of the tax commission as a reviewing body; it has not become the reviewer of tax commission action in intercounty equalization.
[556]*556If a county believes itself aggrieved by the determination of the State Tax Commission concerning intercounty equalization, it may seek judicial review asserting fraud or error of law.
II.
The provisions of the Administrative Procedures Act, MCLA 24.201 et seq.; MSA 3.560(101) et seq. (APA), do not apply to intercounty equalization proceedings before the State Tax Commission.
Plaintiffs and the minority opinion herein rely on this Court’s recent opinion in Cooper Township v State Tax Commission, 393 Mich 58; 222 NW2d 900 (1974), as authority for requiring the State Tax Commission to operate in accordance with thv APA provisions.
Cooper Township, supra, and Ann Arbor Township v State Tax Commission, 393 Mich 682; 227 NW2d 784 (1975), both dealt with intracounty equalization. What we deal with in the instant case is intercounty equalization, a very different situation. The intercounty equalization process is replete with statutory deadlines, among which are the following:
(a) MCLA 211.34; MSA 7.52 requires that the county commissioners equalize their respective counties during the April session.
(b) MCLA 209.5; MSA 7.605 orders the county commissioners to forward their tabular statements (equalization reports) to the State Tax Commission by the first Monday in May.
(c) MCLA 209.2; MSA 7.602 orders the State Board of Equalization to convene on the second Monday in May to equalize assessments.
(d) MCLA 209.4; MSA 7.604, requires the board to prepare a tabular statement showing, by coun[557]*557ties, the total assessed valuation, the valuation as equalized by the commissioners, the previous year’s state equalized valuation, and current year’s recommended values. These figures must be forwarded to the county clerks. In addition to providing for the tabular statement described above, it provides for the State Board of Equalization to remain in session and finally conclude state equalization on the fourth Monday in May. Representatives of the several counties are heard on the fourth Monday in May, at which time the board determines the relative valuation of the 83 counties and adds to or deducts from the assessed values presented to it a sum which produces 50% of true cash value.
Despite these limitations, plaintiffs assert, and the minority opinion agrees, that state equalization must be conducted pursuant to the requirements of the Administrative Procedures Act which would conceivably require introduction into evidence of approximately 162,492 pages of record for 1974, and 70,000 pages for 1973, allow for the cross-examination of approximately 75 employees of the State Tax Commission, and allow counsel for 83 counties to submit and resubmit proposed findings of fact and conclusions of law. Presumably, the State Tax Commission, the adversary party according to plaintiffs, would have a right to review the evidence of the 83 counties, and cross-examine the county commissioners, or the equalization director of each county.
This procedure would make it virtually impossible to comply with the statutory deadlines, and would impede the apportionmept and collection of taxes necessary to numerous state support programs.
We are dealing with a question of legislative [558]*558intent. If it considered this problem, it is most unlikely that the Legislature intended to make one long-established statutory system unworkable by imposing another procedure upon it.
The language of the APA does not require the minority’s result. The act refers to a "contested case”. Who are the contestants in state equalization proceedings? Apparently, the argument is that they are the counties and the State Tax Commission. While they may become adversaries in subsequent litigation in the Court of Appeals or this Court, it stretches the concept of a "contested case” to denominate the commission an adversary during a proceeding before it.
This situation again contrasts with that of intracounty equalization present in Cooper Township, where we recognized that "the township and the county become the adversary parties in an equalization hearing held before the State Tax Commission”. 393 Mich 58, 70, n 3.
In Fisher-New Center Co v State Tax Commission, 381 Mich 713; 167 NW2d 263 (1969), we held that individual taxpayer appeals are contested cases within the APA. The Legislature then passed 1969 PA 270, which exempted State Tax Commission proceedings from the APA contested case provisions. In Cooper Township, supra, we held that statute did not apply to intracounty equalization matters because the Legislature did not amend the county equalization statute, MCLA 211.34; MSA 7.52, as it did the individual assessment statute, MCLA 211.152; MSA 7.210. It does not follow, however, that such analysis requires us to apply the APA to intercounty equalization. There has never been a right of appeal to an administrative agency from intercounty equalization. Therefore, it would be a meaningless gesture [559]*559for the Legislature to declare that the APA does not apply to a. nonexistent proceeding. We hold that the APA does not apply to intercounty equalization proceedings before the State Tax Commission.
Levin, Coleman, and Fitzgerald, JJ., concurred with Kavanagh, C. J.
Ryan, J., took no part in the decision of this case.