Owners of White Flint Mall, the premier upscale shopping center in Montgomery County, figured their 1988 property tax assessment was too high. So, in tried and true tradition, they fought back.

Not only did they lose their appeal, but principals Theodore Lerner and Albert Abramson actually saw their assessments go up another 17 percent.

The Maryland Tax Court in a decision last week ruled that the state's original assessment of the property on Rockville Pike should be raised $19 million -- from the $111 million first disputed by the mall's owners to $130 million.

Montgomery County officials, who pressed the case for the last two years, estimated the increase in assessment will result in an additional $450,000 in revenue for the county this year. Already this year, White Flint has paid $1.3 million in real estate taxes.

Lou D'Ovidio, the county's public advocate for assessments and taxation who pressed the case, said it was a good example of his office raising questions that serve and help the tax-paying public.

Joseph V. Truhe Jr., the attorney who represented the White Flint Limited Partnership led by Lerner and Abramson, said he sees it as a case of a taxpayer being penalized for exercising basic rights.

According to D'Ovidio, the mall's owners had originally appealed the state's January 1988 assessment of its property, arguing that the assessor's estimate was $3 million too high. The Property Tax Assessment Appeals Board agreed with the state and affirmed the assessment at $111 million.

The mall's owners decided not to appeal. D'Ovidio's office, which had been monitoring the situation, had a different view. Believing the property was really worth more, the county hired its own appraiser and went to Maryland Tax Court.

A three-judge panel of that court in an oral decision last week agreed with the county and its appraiser that the property was worth $130 million.

Truhe said the decision of the Tax Court relating to value is final, although matters of law can be appealed and there can be a reconsideration. He said the firm is looking at the case to decide its next step.

D'Ovidio said the decision is expected to set a precedent for how other large shopping malls will be assessed, a point disputed by Truhe.

The Montgomery County office of the Public Advocate for Assessments and Taxation was created in 1975 as a way essentially to double-check the work of state assessors. County officials who created the office, which is the only one in the state, believed that residential and commercial properties were not being assessed and taxed fairly.

Montgomery County is wrestling with how to close a projected budget deficit of $25 million. "Every little bit helps," county budget officer Timothy Firestine said of the extra revenue from White Flint.