ANNAPOLIS, NOV. 28 -- The head of a commission proposing an $800 million tax increase for Maryland defended the idea today as one of "fundamental fairness" toward poor parts of the state that should transcend the concerns of suburban taxpayers and businesses footing most of the bill.

R. Robert Linowes, officially releasing a three-year study that proposes a broad restructuring of the state's tax code, acknowledged that the plan's mix of higher income, sales, and personal property taxes will be difficult for the state's 188 legislators to swallow in the face of taxpayer anxiety over government spending.

The proposal sets up what is expected to be an intense and heavily lobbied fight over the future of state taxes, the first such debate in a quarter-century and one that will focus on leveling disparities in wealth among the state's 23 counties and Baltimore.

Linowes said he hoped the package on average would mean lower taxes for most Marylanders, and said it should not be picked apart in the General Assembly by lobbyists, special interest groups and others with narrow concerns. With much of the new money slated for school, road and other programs in poorer counties, Linowes said the plan represents an investment of social justice.

"It's an opportunity to build a better future for the whole state," Linowes said shortly after the Commission on State Taxes and Tax Structure, which he heads, formally adopted its report to Gov. William Donald Schaefer. "We can't expect the state and its people to achieve their potential if we think narrowly . . . . The turf is the entire state, not its individual jurisdictions.

"Are we prepared to say we don't want to provide educational opportunities for every child . . . . Are we unwilling to help our fellow citizens?"

The Linowes package, which would increase state income taxes for the wealthiest third of Maryland taxpayers, is already meeting resistance from legislative leaders, who say voters in November voiced an anti-tax sentiment that they hesitate to ignore.

Today, business lobbyists added their voice to the chorus of complaints against a plan that would also raise the sales tax from 5 cents on the dollar to 5 1/2 cents, and expand it to cover an array of now untaxed goods and services, including law work, car repair, cigarettes and cable television.

"Our basic position is no new taxes, no new impositions on the business sector because of the adjustments in the area economy," said Robert N. Gray, assistant executive vice president of the Greater Washington Board of Trade.

Schaefer, meanwhile, urged legislators to overlook strictly local concerns and adopt the entire package because of its importance to poorer areas. Baltimore, in particular, would get a $150 million windfall in aid for schools, transportation and general government operations, or one-third of all the money sent back under the plan to local governments. The state would get about $345 million for its general fund.

"You can protect your constituents, but there are other considerations: the state as a whole," Schaefer said.

Montgomery County, home to many of the wealthy taxpayers hit hardest by the proposal, would receive about $12.4 million. Of particular concern in that county is the proposal to restrict the state's contributions to teachers' pensions, one of the few aid programs that benefits Montgomery disproportionately because its teachers are paid more and stay longer in the system.

The $63 million to be received by Prince George's County is second only to Baltimore, and puts that county's powerful legislative delegation in a quandary over whether to back tax increases they know are unpopular, or support a package that could help schools.

"I would be able to support something that is good for my district," said Del. James C. Rosapepe (D-Prince George's). "I would not support raising additional taxes unless the average middle-class taxpayer gets relief."

Linowes's defense of the plan came as attention shifted from the commission's three-year job of sorting out the state's tax code, to a potentially more frustrating venture: selling its ideas to the public and elected officials.

The commission's main argument is bound to require a good deal of salesmanship. The panel estimates that even while raising $800 million for state and local governments, most Maryland taxpayers will face a lower overall tax burden because of the plan's combination of income-tax cuts for poorer families and property tax relief for all homeowners. Those features, Linowes said, would offset the effect of higher sales taxes, higher income-tax rates for wealthier families and a new 2 percent annual levy on cars and boats.

He said legislators must be convinced that with some jurisdictions unable to pay for adequate schools, and governement at all levels strapped to maintain services, the issue is not whether to raise taxes, but who should bear the burden.

"This proposal does not ask that money be raised for its own sake," Linowes said, calling it a "fresh approach to how we tax and how we spend."